Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Reopening of assessment u/s 147 - reasons to believe - The High court observes that all the issues raised in the notice for reopening were indeed subject to discussion during the assessment proceedings. Despite the absence of explicit mention in the assessment order, the court holds that the Assessing Officer had considered the petitioner's submissions on these matters. As a result, the court concludes that the reopening of the assessment is merely based on a change of opinion, which does not constitute a valid reason to believe that income has escaped assessment.
Reopening of assessment u/s 147 - reasons to believe - The High court observes that all the issues raised in the notice for reopening were indeed subject to discussion during the assessment proceedings. Despite the absence of explicit mention in the assessment order, the court holds that the Assessing Officer had considered the petitioner's submissions on these matters. As a result, the court concludes that the reopening of the assessment is merely based on a change of opinion, which does not constitute a valid reason to believe that income has escaped assessment.
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