Prospective valuation amendment limits reassessment: unamended fair market value reference could not justify reopening based on a registered valuer's ...
Exemption for examination-related services rejected where recipients were commercial entities; suppression sustained extended limitation and penalties...
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Reopening of assessment u/s 147 - non independent application of mind by AO - Scope of borrowed satisfaction - The Appellate Tribunal found that the reopening was solely based on assumptions without concrete evidence linking the assessee to the alleged transactions. It was observed that the Assessing Officer did not adequately apply his mind before issuing the notice, and the conclusions were merely a reproduction of the investigation report. Citing precedents, the Tribunal emphasized the necessity of an independent application of mind by the Assessing Officer and concluded that the notice was invalid.
Reopening of assessment u/s 147 - non independent application of mind by AO - Scope of borrowed satisfaction - The Appellate Tribunal found that the reopening was solely based on assumptions without concrete evidence linking the assessee to the alleged transactions. It was observed that the Assessing Officer did not adequately apply his mind before issuing the notice, and the conclusions were merely a reproduction of the investigation report. Citing precedents, the Tribunal emphasized the necessity of an independent application of mind by the Assessing Officer and concluded that the notice was invalid.
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