Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Reopening of assessment u/s 147 - reasons to believe - Having regard to the material on record, we are of the view that the Assessing Officer has initiated the proceedings not only on the information received from the concerned department but based upon his independent satisfaction and other available material to form a belief with regard to the escape assessment of income - AO is justified in reopening the assessment of the assessee - HC
Reopening of assessment u/s 147 - reasons to believe - Having regard to the material on record, we are of the view that the Assessing Officer has initiated the proceedings not only on the information received from the concerned department but based upon his independent satisfaction and other available material to form a belief with regard to the escape assessment of income - AO is justified in reopening the assessment of the assessee - HC
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