Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
Reopening of assessment u/s 147 - The High Court observed that the reasons provided by the Assessing Officer for reopening the assessment did not establish a live link between the information received and the belief that income had escaped assessment. There was no clear allegation of failure to disclose material facts by the petitioner. The court concluded that the reassessment was merely based on a change of opinion by the Assessing Officer, which did not justify reopening the assessment. It highlighted that a reason to suspect is not the same as a reason to believe, and there must be a rational connection between the material and the belief of income escapement.
Reopening of assessment u/s 147 - The High Court observed that the reasons provided by the Assessing Officer for reopening the assessment did not establish a live link between the information received and the belief that income had escaped assessment. There was no clear allegation of failure to disclose material facts by the petitioner. The court concluded that the reassessment was merely based on a change of opinion by the Assessing Officer, which did not justify reopening the assessment. It highlighted that a reason to suspect is not the same as a reason to believe, and there must be a rational connection between the material and the belief of income escapement.
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