Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
Reopening of a completed scrutiny assessment is invalid where tax deducted at source on salary payments was not claimed as expenditure or as a statutory deduction, but was mistakenly treated as claimed through a misreading of the tax audit report. Where the deduction position and tax withholding had already been examined and accepted during original scrutiny, reopening on the same material without fresh tangible material constitutes an impermissible change of opinion and demonstrates non-application of mind. The reassessment notice and consequential order were quashed.
Reopening of a completed scrutiny assessment is invalid where tax deducted at source on salary payments was not claimed as expenditure or as a statutory deduction, but was mistakenly treated as claimed through a misreading of the tax audit report. Where the deduction position and tax withholding had already been examined and accepted during original scrutiny, reopening on the same material without fresh tangible material constitutes an impermissible change of opinion and demonstrates non-application of mind. The reassessment notice and consequential order were quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
