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...
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
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4782
Join Channel
TaxTMI 
