Electronic evidence and search statements in tax assessments require authenticity review and corroboration, while procedural manuals lack statutory fo...
Tariff rate quota authorisations govern preferential imports of specified New Zealand goods through export certification and electronic customs debiti...
Electronic Continuity Bond Registration replaces manual container permissions, with quarterly reporting and re-export monitoring for duty-free contain...
Reopening of assessment u/s 147 - Change of opinion - We are of a strong conviction that in the garb of reopening the case of the assessee he had on the basis of the same set of facts as were available on record at the time of framing of the original assessment, tried to substitute his view as against that of his predecessor. In fact, we are unable to comprehend as to what new “material” or “information” had came to the notice of the A.O after the framing of the original assessment, which would have justified the reopening of its case. - AT
Reopening of assessment u/s 147 - Change of opinion - We are of a strong conviction that in the garb of reopening the case of the assessee he had on the basis of the same set of facts as were available on record at the time of framing of the original assessment, tried to substitute his view as against that of his predecessor. In fact, we are unable to comprehend as to what new “material” or “information” had came to the notice of the A.O after the framing of the original assessment, which would have justified the reopening of its case. - AT
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TaxTMI 
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