Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Validity of reopening of assessment u/s 147 - assumption of jurisdiction by the ld. AO u/s.147 - He had categorically stated in the reasons that from the records these transactions were found. That itself goes to prove that the ld. AO had gone into the assessment records again and had sought to entertain the change of opinion on the same set of facts available in the records.Hence, the reopening of assessment in respect of capital gain on sale of TCS Ltd. shares and re-investment in preference shares of Tata Sons Ltd., is declared as bad in law. - AT
Validity of reopening of assessment u/s 147 - assumption of jurisdiction by the ld. AO u/s.147 - He had categorically stated in the reasons that from the records these transactions were found. That itself goes to prove that the ld. AO had gone into the assessment records again and had sought to entertain the change of opinion on the same set of facts available in the records.Hence, the reopening of assessment in respect of capital gain on sale of TCS Ltd. shares and re-investment in preference shares of Tata Sons Ltd., is declared as bad in law. - AT
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