Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
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...
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Validity of reopening of assessment u/s 147 - Reason to believe - The court scrutinized the purported tangible material for reopening, which consisted of audit objections received after the original assessment. However, it noted that the objections had been duly explained by the petitioner during the original assessment proceedings, and the assessing officer had found the explanations satisfactory. Therefore, the court concluded that there was no fresh tangible material justifying the reopening of the assessment.
Validity of reopening of assessment u/s 147 - Reason to believe - The court scrutinized the purported tangible material for reopening, which consisted of audit objections received after the original assessment. However, it noted that the objections had been duly explained by the petitioner during the original assessment proceedings, and the assessing officer had found the explanations satisfactory. Therefore, the court concluded that there was no fresh tangible material justifying the reopening of the assessment.
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