Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Objective characteristics govern magnesium bis-glycinate chelate classification as an amino-acid coordination compound, not a food preparation or anti...
Independent professional certification requires pleaded knowledge or complicity for criminal liability; untimely complaints remain barred by limitatio...
Reopening of assessment u/s 147 - The notice under Section 148 has been issued purely by way of change of opinion relying on the same set of primary facts which had been submitted by petitioner during the original assessment proceedings. In our view, the usage of expression in the reasons “there has been escapement of income by reason of failure on the part of the assessee to disclose fully and truly all material facts” is clearly made as an attempt to take the case out of the restrictions imposed by proviso to Section 147 of the Act. - HC
Reopening of assessment u/s 147 - The notice under Section 148 has been issued purely by way of change of opinion relying on the same set of primary facts which had been submitted by petitioner during the original assessment proceedings. In our view, the usage of expression in the reasons “there has been escapement of income by reason of failure on the part of the assessee to disclose fully and truly all material facts” is clearly made as an attempt to take the case out of the restrictions imposed by proviso to Section 147 of the Act. - HC
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