Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
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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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