Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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Reopening of assessment - reason to believe - The Court evaluates the concept of "true and full disclosure" as mandated by Section 147, considering relevant legal precedents. It emphasizes that the duty lies on the assessee to disclose fully and truly all material facts necessary for assessment. The Court finds that the petitioner's submission regarding loan transactions does not negate the necessity for disclosure of material facts, particularly regarding cash transactions. Thus, the Court upholds the respondent's contention regarding lack of full disclosure.
Reopening of assessment - reason to believe - The Court evaluates the concept of "true and full disclosure" as mandated by Section 147, considering relevant legal precedents. It emphasizes that the duty lies on the assessee to disclose fully and truly all material facts necessary for assessment. The Court finds that the petitioner's submission regarding loan transactions does not negate the necessity for disclosure of material facts, particularly regarding cash transactions. Thus, the Court upholds the respondent's contention regarding lack of full disclosure.
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