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    September 23, 2026   Case Laws Income Tax
    Genuine hardship permits condonation of delayed Form 10B where bona fide compliance misunderstanding would otherwise defeat charitable exemption.
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    September 23, 2026   Case Laws Income Tax
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    September 23, 2026   Case Laws Income Tax
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    September 23, 2026   Case Laws Income Tax
    Bona fide disclosure and reasonable cause can prevent penalties for under-reported income and delayed tax-audit reporting.
    September 23, 2026   Case Laws Income Tax
    Independent assessment discretion: unauthorised superior-officer consultation can invalidate regular scrutiny assessments by displacing the Assessing ...
    September 23, 2026   Case Laws Income Tax
    Concessional corporate tax option requires full statutory compliance, while disputed additional-depreciation disallowance exceeds return-processing sc...
    September 23, 2026   Case Laws Income Tax
    Foreign-exchange gains on ECB liabilities for indigenous assets fall under section 43AA, not section 43A, for tax computation.
    September 23, 2026   Case Laws Income Tax
    Reassessment for unreturned property sales survives where transfer information, non-filing, and unsupported exemption claims establish a prima facie l...
    September 23, 2026   Case Laws Income Tax
    Tax-inclusive service valuation triggers section 43B disallowance for unpaid GST, while delayed TDS interest remains non-deductible.
    September 23, 2026   Case Laws Income Tax
    Profit-element taxation limits additions for unaccounted flat-sale receipts and grey-market purchases, while reliable search records support partial a...
    September 23, 2026   Case Laws Income Tax
    Documentary substantiation determined tuition and rent claims, while unrefuted seized electronic loan entries supported unexplained-investment additio...
    September 23, 2026   Case Laws Income Tax
    Damaged inventory valuation at lower cost or net realisable value supported deletion of stock revaluation and cash-deposit additions.
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September 23, 2026   Case Laws Income Tax
Genuine hardship permits condonation of delayed Form 10B where bona fide compliance misunderstanding would otherwise defeat charitable exemption.
September 23, 2026   Case Laws Income Tax
Natural justice breaches in import-data additions justified staying recovery while appeal remained pending despite deposit guidance.
September 23, 2026   Case Laws Income Tax
Settlement application eligibility requires a pending assessment when filed, preventing an extra prior-eligibility condition from blocking consideration.
September 23, 2026   Case Laws Income Tax
Adequate Hearing in Faceless Assessments Requires the prescribed response period and meaningful personal-hearing opportunity before assessment.
September 23, 2026   Case Laws Income Tax
Substantial questions of law do not arise where income-tax appeals merely seek reassessment of concurrent factual findings.
September 23, 2026   Case Laws Income Tax
Limitation for reassessments runs from the rectification order when it directs de novo assessment, preserving timely reassessment proceedings.
September 23, 2026   Case Laws Income Tax
Timely return requirement for co-operative deduction supports revision where reassessment ignored eligibility linked to cash-deposit income.
September 23, 2026   Case Laws Income Tax
Cloud software subscription access is not royalty where no copyright or process rights transfer to subscribers.
September 23, 2026   Case Laws Income Tax
Bona fide disclosure and reasonable cause can prevent penalties for under-reported income and delayed tax-audit reporting.
September 23, 2026   Case Laws Income Tax
Independent assessment discretion: unauthorised superior-officer consultation can invalidate regular scrutiny assessments by displacing the Assessing Officer's own judgment.
September 23, 2026   Case Laws Income Tax
Concessional corporate tax option requires full statutory compliance, while disputed additional-depreciation disallowance exceeds return-processing scope.
September 23, 2026   Case Laws Income Tax
Foreign-exchange gains on ECB liabilities for indigenous assets fall under section 43AA, not section 43A, for tax computation.
September 23, 2026   Case Laws Income Tax
Reassessment for unreturned property sales survives where transfer information, non-filing, and unsupported exemption claims establish a prima facie link.
September 23, 2026   Case Laws Income Tax
Tax-inclusive service valuation triggers section 43B disallowance for unpaid GST, while delayed TDS interest remains non-deductible.
September 23, 2026   Case Laws Income Tax
Profit-element taxation limits additions for unaccounted flat-sale receipts and grey-market purchases, while reliable search records support partial additions.
September 23, 2026   Case Laws Income Tax
Documentary substantiation determined tuition and rent claims, while unrefuted seized electronic loan entries supported unexplained-investment addition.
September 23, 2026   Case Laws Income Tax
Damaged inventory valuation at lower cost or net realisable value supported deletion of stock revaluation and cash-deposit additions.
September 23, 2026   Case Laws Customs
Reverse burden for notified gold requires reasonable belief and permits documentary proof of domestic provenance.
September 23, 2026   Case Laws Customs
Customs tariff classification follows material composition and vehicle-specific use, restricting preferential treatment and supporting duty consequences.
September 23, 2026   Case Laws Customs
End-use customs concessions require qualifying manufacture, making scrapped imported cells subject to full duty reversal with interest.

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Home › Highlights › Income Tax › 2023 › March, 2023 › This
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Income Tax

Reopening of assessment u/s 147 - Audit objection - change of...

Audit Objection on Factual Issues Can't Justify Reopening u/s 147; Change of Opinion Isn't Valid Reason.

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Income Tax March 7, 2023 Case Laws AT
Reopening of assessment u/s 147 - Audit objection - change of opinion - Reason to believe - if the audit objection on factual issue and, where, the audit party has quantified escapement, then, definitely, it does not constitute information for reopening of assessment. - AT
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