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October 10, 2026   Case Laws Income Tax
Clubbing of income from gifted property failed where the claim surfaced after reassessment limitation, sustaining capital-gains assessment in spouse's hands.
October 10, 2026   Case Laws Income Tax
Employee stock-option discount qualifies as revenue expenditure, while royalty and service comparables require reliable functional and transactional benchmarking.
October 10, 2026   Case Laws Income Tax
Interest-free own funds negate advance disallowance; share-premium credits require investor-wise verification under the applicable statutory framework.
October 10, 2026   Case Laws Income Tax
Limited-scrutiny assessments restrict tax inquiries, preventing revision for unexamined issues beyond the selected verification scope unless formally converted.
October 10, 2026   Case Laws Income Tax
Business loan waiver qualifies as a revenue loss when the advance is integral to ordinary business activity.
October 10, 2026   Case Laws Income Tax
Special insurance income computation preserves statutory deductions while limiting transfer-pricing, withholding and disallowance adjustments for general insurers.
October 10, 2026   Case Laws Benami Property
Benami procedural amendments apply retrospectively, while enhanced penalties remain prospective and voluntary statements can establish beneficial ownership.
October 10, 2026   Case Laws Customs
Reasonable belief in gold seizures limits confiscation where foreign origin, illicit importation, and conscious involvement remain unproved.
October 10, 2026   Case Laws Customs
Re-import duty exemption requires re-export of the same repaired goods, not substitution with newly manufactured exports.
October 10, 2026   Case Laws Customs
Pre-amendment IGST interest: payments without statutory authority are deposits, placing their refund outside the duty-refund limitation period.
October 10, 2026   Case Laws Customs
Undisposed extension applications under project-import rules may preserve nil-duty eligibility when finalisation documents precede departmental notices.
October 10, 2026   Case Laws Companies Law
Disputed shareholder buy-out valuation prompts interim stay, while minority board representation directions remain temporarily preserved.
October 10, 2026   Case Laws Companies Law
Individual standing in representative company proceedings fails where class remedies exist, and concluded hearings cannot be reopened unilaterally.
October 10, 2026   Case Laws SEBI
Former director liability for investor refunds survives resignation when recovery implements final directions affirmed on appeal.
October 10, 2026   Case Laws SEBI
Inspection rights cover relied-upon regulatory records, not unrestricted access to confidential bank portal and electronic data.
October 10, 2026   Case Laws IBC
IBC clean slate permits defensive set-off but preserves debtor claims and excludes CIRP moratorium from arbitral limitation.
October 9, 2026   Notifications Customs
Dabhol Port customs designation now covers LNG, power-project cargo, shipyard imports, repairs and exports at the designated port.
October 9, 2026   Notifications Indian Laws
Verifiable consent and data audit obligations are clarified through targeted textual corrections to the Digital Personal Data Protection Act.
October 9, 2026   Circulars Customs
Compulsory registration for smartphone screen protectors begins after conformity with the prescribed Indian Standard becomes mandatory.
October 9, 2026   Circulars SEBI
ISIN maturity caps for privately placed debt expand, with separate limits, legacy grandfathering, and exclusions for specified instruments.

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

Reopening of assessment u/s 147 - reason to believe -...

High Court Rules Change of Opinion Insufficient for Reopening Tax Assessment u/s 147, Clarifies Deduction Year.

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Income Tax August 29, 2023 Case Laws HC
Reopening of assessment u/s 147 - reason to believe - commencement date / year for deduction u/s 80IA - Eligible from 1995 or 2000 - scope of change of opinion - We agree with that this is nothing but a case of change of opinion by the A.O. from that held earlier during the course of assessment proceedings and this change of opinion does not constitute justification and/or reasons to believe that income chargeable to tax has escaped assessment. - HC
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