Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Constitutional judicial review permits challenges to ECIRs and connected money-laundering proceedings where coercive action affects fundamental intere...
Validity of reopening of assessment u/s 147 - The High Court analyzed the Supreme Court's decision in Ashish Agarwal and concluded that it did not mandate the reopening of concluded assessments. The procedure outlined in Ashish Agarwal primarily concerned notices that were challenged before various High Courts but had not yet attained finality. The High Court clarified that Ashish Agarwal did not authorize completed assessments to be reopened, especially in cases where no objection had been raised to the initiation of proceedings.
Validity of reopening of assessment u/s 147 - The High Court analyzed the Supreme Court's decision in Ashish Agarwal and concluded that it did not mandate the reopening of concluded assessments. The procedure outlined in Ashish Agarwal primarily concerned notices that were challenged before various High Courts but had not yet attained finality. The High Court clarified that Ashish Agarwal did not authorize completed assessments to be reopened, especially in cases where no objection had been raised to the initiation of proceedings.
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