Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
Reopening of assessment u/s 147 - True and full disclosure of all material facts - It is true that in the assessment order self-disallowances have not been discussed but at the same time it has been a subject of consideration during the assessment proceedings since the Assessing Officer has started from the business income as returned by petitioner, which included self-disallowances debited to the P&L Account. - it is a clear case of change of opinion to take a different view relying on the same set of documents. Change in opinion cannot construe “reason to believe”. - HC
Reopening of assessment u/s 147 - True and full disclosure of all material facts - It is true that in the assessment order self-disallowances have not been discussed but at the same time it has been a subject of consideration during the assessment proceedings since the Assessing Officer has started from the business income as returned by petitioner, which included self-disallowances debited to the P&L Account. - it is a clear case of change of opinion to take a different view relying on the same set of documents. Change in opinion cannot construe “reason to believe”. - HC
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