Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Reopening of assessment u/s 147 - Notice after four years - reopening based on audit objections - The Income Tax Officer must determine for himself what is the effect and consequence of the law mentioned in the audit note and whether in consequence of the law which has come to his notice he can reasonably believe that income had escaped assessment. The basis of his belief must be the law of which he has now become aware. - Further there is nothing under this head to indicate that there was failure on the part of petitioner to truly and fully disclose any fact - Notice and order quashed - however admitted liability of tax by the assessee directed to be paid - HC
Reopening of assessment u/s 147 - Notice after four years - reopening based on audit objections - The Income Tax Officer must determine for himself what is the effect and consequence of the law mentioned in the audit note and whether in consequence of the law which has come to his notice he can reasonably believe that income had escaped assessment. The basis of his belief must be the law of which he has now become aware. - Further there is nothing under this head to indicate that there was failure on the part of petitioner to truly and fully disclose any fact - Notice and order quashed - however admitted liability of tax by the assessee directed to be paid - HC
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