Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
ODR arbitration participation remains mandatory after failed conciliation, while jurisdictional and maintainability objections stay available before t...
Transparency in technical bid evaluation requires disclosed standards and recorded reasons; opaque scoring invalidated tender awards and required fres...
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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