Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
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Reopening of assessment u/s 147 - concept of change of opinion - In cases where the return of an assessee is accepted without scrutiny, the assessing officer enjoys a greater latitude to reopen the assessment. - AO had sufficient material at his command to form a belief that the income chargeable to tax has escaped assessment. There is a clear link between the information available with the assessing officer and his formation of belief that the income chargeable to tax has escaped assessment. - HC
Reopening of assessment u/s 147 - concept of change of opinion - In cases where the return of an assessee is accepted without scrutiny, the assessing officer enjoys a greater latitude to reopen the assessment. - AO had sufficient material at his command to form a belief that the income chargeable to tax has escaped assessment. There is a clear link between the information available with the assessing officer and his formation of belief that the income chargeable to tax has escaped assessment. - HC
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