Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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