Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Reassessment u/s 147 - within 4 years from the end of relevant AY - when no opinion was formed by Ld. AO on any issue during original assessment proceedings and the same was altogether skipped, there would be no bar to reach the requisite satisfaction on the basis of findings in subsequent assessment year - In such a case, deeming fiction of Explanation-2 would come into play and the income shall be deemed to have escaped assessment
Reassessment u/s 147 - within 4 years from the end of relevant AY - when no opinion was formed by Ld. AO on any issue during original assessment proceedings and the same was altogether skipped, there would be no bar to reach the requisite satisfaction on the basis of findings in subsequent assessment year - In such a case, deeming fiction of Explanation-2 would come into play and the income shall be deemed to have escaped assessment
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