Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
Validity of reopening of assessment u/s 147 - the Explanation to the sub-section has nothing to do with “inferences” and deals only with the question whether primary material facts not disclosed could still be said to be constructively disclosed on the ground that with due diligence the Income-tax Officer could have discovered them from the facts actually disclosed. The Explanation has not the effect of enlarging the section, by casting a duty on the assessee to disclose “inferences” to draw the proper inferences being the duty imposed on the Income Tax Officer. Therefore, it can be concluded that while the duty of the assessee is to disclose fully and truly all primary relevant facts, it does not extend beyond this. - HC
Validity of reopening of assessment u/s 147 - the Explanation to the sub-section has nothing to do with “inferences” and deals only with the question whether primary material facts not disclosed could still be said to be constructively disclosed on the ground that with due diligence the Income-tax Officer could have discovered them from the facts actually disclosed. The Explanation has not the effect of enlarging the section, by casting a duty on the assessee to disclose “inferences” to draw the proper inferences being the duty imposed on the Income Tax Officer. Therefore, it can be concluded that while the duty of the assessee is to disclose fully and truly all primary relevant facts, it does not extend beyond this. - HC
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