Transaction value rejection requires reliable corroboration; refundable VAT is excluded and temporary registration does not defeat new-vehicle exempti...
Appellate jurisdiction remains available where a wrist-worn gold ornament cannot conclusively be characterised as imported baggage at the preliminary ...
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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