Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Validity of Reopening of assessment u/s 147 - The Tribunal emphasized the principle that for reassessment under Section 147 of the Income Tax Act, the onus is on the revenue to show that there was a failure by the assessee to disclose fully and truly all material facts necessary for assessment. The Tribunal held that mere change of opinion or re-examination of facts already on record without new tangible material cannot justify reassessment proceedings, especially when initiated after the expiry of four years from the end of the relevant assessment year. - AT
Validity of Reopening of assessment u/s 147 - The Tribunal emphasized the principle that for reassessment under Section 147 of the Income Tax Act, the onus is on the revenue to show that there was a failure by the assessee to disclose fully and truly all material facts necessary for assessment. The Tribunal held that mere change of opinion or re-examination of facts already on record without new tangible material cannot justify reassessment proceedings, especially when initiated after the expiry of four years from the end of the relevant assessment year. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
