Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Initiation of reassessment proceedings - AO has nowhere brought out as to how the claim of depreciation at higher level in the original assessment proceedings can be construed as failure of the assessee to disclose fully and truly all facts necessary for assessment. It is only change of the opinion by the AO, which in our considered opinion, cannot lead to initiation of reassessment proceedings after a period of four years from the end of the relevant assessment year. - AT
Initiation of reassessment proceedings - AO has nowhere brought out as to how the claim of depreciation at higher level in the original assessment proceedings can be construed as failure of the assessee to disclose fully and truly all facts necessary for assessment. It is only change of the opinion by the AO, which in our considered opinion, cannot lead to initiation of reassessment proceedings after a period of four years from the end of the relevant assessment year. - AT
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