Faceless assessment and registration procedures are updated through electronic communication, revised recovery rules, extended deadlines, and replacem...
Risk-based selective vessel boarding requires accurate declarations and preserves master and agent liability where physical inspections are not select...
Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Reopening of assessment u/s 147 - Non production of agreement before the AO - It is nobody’s case that there existed any such agreement, which ought to have been produced but was not produced. Rather AO intends to imply that in the absence of any such agreement, the benefit ought not to have been granted to the Petitioner in the scrutiny assessment. There cannot be any failure to disclose fully and truly, if there was no such document as such. This, in our opinion, is nothing but a change of opinion - HC
Reopening of assessment u/s 147 - Non production of agreement before the AO - It is nobody’s case that there existed any such agreement, which ought to have been produced but was not produced. Rather AO intends to imply that in the absence of any such agreement, the benefit ought not to have been granted to the Petitioner in the scrutiny assessment. There cannot be any failure to disclose fully and truly, if there was no such document as such. This, in our opinion, is nothing but a change of opinion - HC
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TaxTMI 
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