Chapter XIX exclusion applies to payments received by the International Rice Research Institute, subject to specified privileges and immunities condit...
Reassessment beyond four years after a completed scrutiny assessment requires recorded reasons based on tangible material with a live link to escaped income and a failure of full and true disclosure of material facts. A post-assessment investigation concerning alleged share overvaluation, underlying assets, use of sale proceeds and capital-gains deduction supplied a prima facie basis for reopening. Change of opinion applies only where the original proceeding consciously formed an opinion; an intimation under Section 143(1) is not an assessment, and no prior view on the relevant valuation or deduction issues was formed under Section 143(3). The reassessment notices were therefore valid.
Reassessment beyond four years after a completed scrutiny assessment requires recorded reasons based on tangible material with a live link to escaped income and a failure of full and true disclosure of material facts. A post-assessment investigation concerning alleged share overvaluation, underlying assets, use of sale proceeds and capital-gains deduction supplied a prima facie basis for reopening. Change of opinion applies only where the original proceeding consciously formed an opinion; an intimation under Section 143(1) is not an assessment, and no prior view on the relevant valuation or deduction issues was formed under Section 143(3). The reassessment notices were therefore valid.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
