Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Reopening of assessment u/s 147 - Reason to believe - The notice was based on alleged undisclosed cash deposits made by the trust during a specific financial year. The trust objected to the reopening, arguing that all income was duly recorded and offered for taxation. The High court found that the reasons provided for reopening were unsubstantiated and lacked a rational connection to establish income escapement. It emphasized the impermissibility of fishing expeditions without concrete evidence. Consequently, the court set aside the notice of reopening.
Reopening of assessment u/s 147 - Reason to believe - The notice was based on alleged undisclosed cash deposits made by the trust during a specific financial year. The trust objected to the reopening, arguing that all income was duly recorded and offered for taxation. The High court found that the reasons provided for reopening were unsubstantiated and lacked a rational connection to establish income escapement. It emphasized the impermissibility of fishing expeditions without concrete evidence. Consequently, the court set aside the notice of reopening.
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