Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
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Reassessment proceeding under Section 147 was made to form change of opinion and therefore, it would clearly amount to reviewing the original order of assessment u/s 147 under the pretext of reassessment. We make it clear that in the reassessment proceedings u/s 147, the original assessment order cannot be reviewed. Proceedings also cannot be initiated merely because there is a possibility of change of opinion. - HC
Reassessment proceeding under Section 147 was made to form change of opinion and therefore, it would clearly amount to reviewing the original order of assessment u/s 147 under the pretext of reassessment. We make it clear that in the reassessment proceedings u/s 147, the original assessment order cannot be reviewed. Proceedings also cannot be initiated merely because there is a possibility of change of opinion. - HC
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