Customs seizure safeguards prevent detention-based limitation avoidance and invalidate provisional release conditions for imported vehicles under an i...
Preliminary reassessment proceedings generally require statutory remedies unless jurisdiction is wholly absent or mandatory conditions are patently br...
Agricultural land classification requires cumulative factual indicators, while industrial-purpose land and absent agricultural use defeat reinvestment...
Reopening of assessment - reason to believe - onus to prove - The High court noted that reassessment beyond four years from the end of the relevant assessment year is permissible only if there is a failure by the taxpayer to disclose fully and truly all material facts necessary for assessment. - The court observed that the petitioner had disclosed all primary facts related to the waiver of loans in the original assessment proceedings. It was emphasized that the production of account books or other evidence does not necessarily amount to full disclosure as required by law. - As such, the reassessment was deemed to be based on a change of opinion, which is not a valid ground for reopening an assessment under the relevant sections of the Act.
Reopening of assessment - reason to believe - onus to prove - The High court noted that reassessment beyond four years from the end of the relevant assessment year is permissible only if there is a failure by the taxpayer to disclose fully and truly all material facts necessary for assessment. - The court observed that the petitioner had disclosed all primary facts related to the waiver of loans in the original assessment proceedings. It was emphasized that the production of account books or other evidence does not necessarily amount to full disclosure as required by law. - As such, the reassessment was deemed to be based on a change of opinion, which is not a valid ground for reopening an assessment under the relevant sections of the Act.
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