Prospective valuation amendment limits reassessment: unamended fair market value reference could not justify reopening based on a registered valuer's ...
Exemption for examination-related services rejected where recipients were commercial entities; suppression sustained extended limitation and penalties...
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Validity of jurisdiction assumed by AO u/s 147 - Assessment was not complete based not valuation report - While a formal rejection of books may not, at times, be possibly necessary an abstract position of law, an implied dissatisfaction on the books could not be gauged either from the original assessment or from the attendant office note. - CIT(A) has also made reference to various other judgments and has come to the conclusion that ingredients of Section 147 of the Act are not fulfilled in the instant case and consequently reopening is not permissible in the facts and circumstances of the case - AT
Validity of jurisdiction assumed by AO u/s 147 - Assessment was not complete based not valuation report - While a formal rejection of books may not, at times, be possibly necessary an abstract position of law, an implied dissatisfaction on the books could not be gauged either from the original assessment or from the attendant office note. - CIT(A) has also made reference to various other judgments and has come to the conclusion that ingredients of Section 147 of the Act are not fulfilled in the instant case and consequently reopening is not permissible in the facts and circumstances of the case - AT
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