Opportunity to respond to jurisdictional reports is mandatory before customs settlement duty enhancement; connected applications require consistent ad...
Specific customs headings for scaffolding components prevail over general classification, invalidating misclassification proceedings and enabling with...
Liquidator appointment under Section 34 requires consideration of creditor recommendations, valid professional authorisation, and preservation of vali...
Reopening of the assessment u/s 147/148 - The "reason to believe" would mean cause or justification. If the Assessing Officer has cause or justification to know or suppose that income had escaped assessment, he can be said to have reason to believe that an income had escaped assessment. The expression cannot be read to mean that the Assessing Officer should have finally ascertained the fact by legal evidence or conclusion and what is required is "reason to believe", but not the established fact of escapement of income. - At the stage of issue of notice, the only question is whether there was relevant material on which a reasonable person could have formed a requisite belief. - AT
Reopening of the assessment u/s 147/148 - The "reason to believe" would mean cause or justification. If the Assessing Officer has cause or justification to know or suppose that income had escaped assessment, he can be said to have reason to believe that an income had escaped assessment. The expression cannot be read to mean that the Assessing Officer should have finally ascertained the fact by legal evidence or conclusion and what is required is "reason to believe", but not the established fact of escapement of income. - At the stage of issue of notice, the only question is whether there was relevant material on which a reasonable person could have formed a requisite belief. - AT
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