Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
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...
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
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