Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
Validity of Reopening of assessment u/s 147 - Existence of reason to believe - The issue squarely falls in the realm “change of opinion”. In our view, the only reason that in the succeeding assessment years, the Assessing Officer has come to a different opinion, by itself, may not be a ground to reopen the assessment for an earlier year, wherein a view was conclusively recorded by the concerned Assessing Officer. - HC
Validity of Reopening of assessment u/s 147 - Existence of reason to believe - The issue squarely falls in the realm “change of opinion”. In our view, the only reason that in the succeeding assessment years, the Assessing Officer has come to a different opinion, by itself, may not be a ground to reopen the assessment for an earlier year, wherein a view was conclusively recorded by the concerned Assessing Officer. - HC
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