Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
The ITAT Nagpur considered the validity of reassessment proceedings u/s 147. The AO issued notice beyond four years alleging capital gain on "Sale of Vehicles" escaped assessment. The tribunal held that the AO's reasons for reopening were a change of opinion as the issue was already examined during the original assessment. The AO did not prove failure to disclose material facts, as the assessee had provided sale agreements. Without new evidence, the AO lacked jurisdiction u/s 147 after four years. Since no failure to disclose facts was alleged, the reassessment was deemed invalid. Decision favored the assessee. - AO had initially made an addition u/s 68 regarding the sale of vehicles. The re-assessment proceedings attempted to reclassify this under u/s 50 or 41(2), which the Tribunal found to be a mere change of opinion and not permissible.
The ITAT Nagpur considered the validity of reassessment proceedings u/s 147. The AO issued notice beyond four years alleging capital gain on "Sale of Vehicles" escaped assessment. The tribunal held that the AO's reasons for reopening were a change of opinion as the issue was already examined during the original assessment. The AO did not prove failure to disclose material facts, as the assessee had provided sale agreements. Without new evidence, the AO lacked jurisdiction u/s 147 after four years. Since no failure to disclose facts was alleged, the reassessment was deemed invalid. Decision favored the assessee. - AO had initially made an addition u/s 68 regarding the sale of vehicles. The re-assessment proceedings attempted to reclassify this under u/s 50 or 41(2), which the Tribunal found to be a mere change of opinion and not permissible.
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