Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
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...
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Reopening of assessment u/s 147 - The words ‘ reason to believe’ appearing in Section 147 cannot mean that the A.O should have finally ascertained the facts. Assessing Officer merely forms a ‘belief’ from the examination he makes and if escaped assessment, it would amount to saying that he has ‘ reason to believe’ that such income has ‘escaped assessment’. The justification for his belief is not to be judged from the standards of proof required for coming to a final decision. - HC
Reopening of assessment u/s 147 - The words ‘ reason to believe’ appearing in Section 147 cannot mean that the A.O should have finally ascertained the facts. Assessing Officer merely forms a ‘belief’ from the examination he makes and if escaped assessment, it would amount to saying that he has ‘ reason to believe’ that such income has ‘escaped assessment’. The justification for his belief is not to be judged from the standards of proof required for coming to a final decision. - HC
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