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    July 3, 2026   Case LawsIncome Tax
    Treaty shipping profits, PE tests and refund interest under India-Mauritius DTAA addressed in the ruling
    July 3, 2026   Case LawsIncome Tax
    DCF valuation of unquoted shares cannot be replaced by NAV, though the Assessing Officer may scrutinise defects.
    July 3, 2026   Case LawsIncome Tax
    Banking tax issues: actuarial employee-benefit provisions, NPA interest, securities valuation and MAT non-applicability to new banks
    July 3, 2026   Case LawsIncome Tax
    PILCOM managing committee status defeated protective tax additions on World Cup receipts and foreign match income.
    July 3, 2026   Case LawsIncome Tax
    Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
    July 3, 2026   Case LawsCustoms
    Burden of proof for notified gold shifts on recovery from controlled premises; penalty sustained but reduced on quantum.
    July 3, 2026   Case LawsCustoms
    Reasonable belief for seizure of gold under customs law must be based on objective material, not suspicion alone.
    July 3, 2026   Case LawsCustoms
    Imported nickel-chromium wire classification: prior co-ordinate bench ruling barred reclassification absent factual change or legal change.
    July 3, 2026   Case LawsCustoms
    Contemporaneous protest and deliberate misdeclaration: re-measurement rejected, but customs penalty set aside for marginal slab overage.
    July 3, 2026   Case LawsCustoms
    EPS-ECU parts classified as steering system components where no independent electrical function exists.
    July 3, 2026   Case LawsCustoms
    Fully mechanised jewellery exports satisfy Replenishment Scheme value addition; customs duty demand and penalties were set aside.
    July 3, 2026   Case LawsCustoms
    Related-party customs valuation: declared prices rejected, deductive and computed methods applied, with SAD exemption denied
    July 3, 2026   Case LawsIBC
    Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
    July 3, 2026   Case LawsIBC
    Bankruptcy filing timeline under Section 121(2) is directory; delay may be condoned on sufficient cause.
    July 3, 2026   Case LawsIBC
    Claim verification in insolvency: unsupported farmer compensation failed, and lease charges were limited to the insolvency commencement date.
    July 3, 2026   Case LawsIBC
    Valid service through registered email sustains Section 7 admission for interest default and revived loan dues.
    July 3, 2026   Case LawsIBC
    Registered homebuyer claims in CIRP records survive delay when notice is absent and allotment details are documented.
    July 3, 2026   Case LawsMoney Laundering
    Inter-agency sharing under PMLA upheld where prima facie extremist-funding material justified continued investigation at early stage.
    July 3, 2026   Case LawsMoney Laundering
    Continuing money-laundering doctrine sustains provisional attachment where proceeds of crime are dealt with after predicate offence.
    July 3, 2026   Case LawsService Tax
    Overseas services consumed abroad were outside reverse charge tax, and the demand failed on classification and limitation.
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    July 3, 2026   Case Laws Income Tax
    Treaty shipping profits, PE tests and refund interest under India-Mauritius DTAA addressed in the ruling
    July 3, 2026   Case Laws Income Tax
    DCF valuation of unquoted shares cannot be replaced by NAV, though the Assessing Officer may scrutinise defects.
    July 3, 2026   Case Laws Income Tax
    Banking tax issues: actuarial employee-benefit provisions, NPA interest, securities valuation and MAT non-applicability to new banks
    July 3, 2026   Case Laws Income Tax
    PILCOM managing committee status defeated protective tax additions on World Cup receipts and foreign match income.
    July 3, 2026   Case Laws Income Tax
    Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed.
    July 3, 2026   Case Laws Customs
    Burden of proof for notified gold shifts on recovery from controlled premises; penalty sustained but reduced on quantum.
    July 3, 2026   Case Laws Customs
    Reasonable belief for seizure of gold under customs law must be based on objective material, not suspicion alone.
    July 3, 2026   Case Laws Customs
    Imported nickel-chromium wire classification: prior co-ordinate bench ruling barred reclassification absent factual change or legal change.
    July 3, 2026   Case Laws Customs
    Contemporaneous protest and deliberate misdeclaration: re-measurement rejected, but customs penalty set aside for marginal slab overage.
    July 3, 2026   Case Laws Customs
    EPS-ECU parts classified as steering system components where no independent electrical function exists.
    July 3, 2026   Case Laws Customs
    Fully mechanised jewellery exports satisfy Replenishment Scheme value addition; customs duty demand and penalties were set aside.
    July 3, 2026   Case Laws Customs
    Related-party customs valuation: declared prices rejected, deductive and computed methods applied, with SAD exemption denied
    July 3, 2026   Case Laws IBC
    Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law.
    July 3, 2026   Case Laws IBC
    Bankruptcy filing timeline under Section 121(2) is directory; delay may be condoned on sufficient cause.
    July 3, 2026   Case Laws IBC
    Claim verification in insolvency: unsupported farmer compensation failed, and lease charges were limited to the insolvency commencement date.
    July 3, 2026   Case Laws IBC
    Valid service through registered email sustains Section 7 admission for interest default and revived loan dues.
    July 3, 2026   Case Laws IBC
    Registered homebuyer claims in CIRP records survive delay when notice is absent and allotment details are documented.
    July 3, 2026   Case Laws Money Laundering
    Inter-agency sharing under PMLA upheld where prima facie extremist-funding material justified continued investigation at early stage.
    July 3, 2026   Case Laws Money Laundering
    Continuing money-laundering doctrine sustains provisional attachment where proceeds of crime are dealt with after predicate offence.
    July 3, 2026   Case Laws Service Tax
    Overseas services consumed abroad were outside reverse charge tax, and the demand failed on classification and limitation.

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

      Reopening of assessment u/s 147 - Change of opinion - Once the...

      Reopening Tax Assessment u/s 147 Not Justified if Based Solely on Change of Opinion After Full Disclosure.

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      Income TaxOctober 16, 2023Case LawsHC
      Reopening of assessment u/s 147 - Change of opinion - Once the assessee makes a true and full disclosure of the primary facts at the time of the original assessment and which could have been discovered with due diligence by the Income Tax Officer, drawing an inference which appears subsequently to be alone, is a mere change of opinion - HC
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