Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Reopening of assessment u/s 147 - Change of opinion - The reopening of the assessment is nothing but a mere change of opinion on the part of AO. If the AO could not discover even with due diligence, the petitioner cannot be blamed for that. If the AO did not examine the issue of allowability of the deduction during the course of regular assessment, the revenue has no jurisdiction to reopen the assessment. - HC
Reopening of assessment u/s 147 - Change of opinion - The reopening of the assessment is nothing but a mere change of opinion on the part of AO. If the AO could not discover even with due diligence, the petitioner cannot be blamed for that. If the AO did not examine the issue of allowability of the deduction during the course of regular assessment, the revenue has no jurisdiction to reopen the assessment. - HC
Note: It is a system-generated summary and is for quick reference only.