Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
Revisional jurisdiction over export quota premium deductions requires both error and Revenue prejudice; a permissible assessment view cannot be displa...
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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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