Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Constitutional judicial review permits challenges to ECIRs and connected money-laundering proceedings where coercive action affects fundamental intere...
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 
of 4805
Join Channel
TaxTMI 
