Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
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Reassessment under Section 147 cannot be used to review conclusions reached in an original scrutiny assessment. Where the Assessing Officer had specifically examined depreciation claims, deductions, exempt-income expenditure and pre-production income, reopening based only on the same assessment record and a successor officer's different inference constitutes a change of opinion. In the absence of fresh tangible material, a false statement, or failure to make full and true disclosure of material facts, no jurisdictional reason to believe that income escaped assessment arises. The reassessment was therefore quashed and the revenue's appeal dismissed.
Reassessment under Section 147 cannot be used to review conclusions reached in an original scrutiny assessment. Where the Assessing Officer had specifically examined depreciation claims, deductions, exempt-income expenditure and pre-production income, reopening based only on the same assessment record and a successor officer's different inference constitutes a change of opinion. In the absence of fresh tangible material, a false statement, or failure to make full and true disclosure of material facts, no jurisdictional reason to believe that income escaped assessment arises. The reassessment was therefore quashed and the revenue's appeal dismissed.
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