Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
The Calcutta High Court examined the validity of reassessment proceedings u/s 147 based on change of opinion regarding the assessee's liability u/s 115JB. The Court found that the original assessment order u/s 143(3) did not address the assessee's tax liability u/s 115JB, indicating a non-speaking and cryptic order. Therefore, the reassessment was not a change of opinion but a valid exercise of power u/s 147. The Court held the ITAT's finding on change of opinion as unsustainable. The ITAT's failure to address the revenue's appeal on the escaped income was noted. The decision favored the revenue.
The Calcutta High Court examined the validity of reassessment proceedings u/s 147 based on change of opinion regarding the assessee's liability u/s 115JB. The Court found that the original assessment order u/s 143(3) did not address the assessee's tax liability u/s 115JB, indicating a non-speaking and cryptic order. Therefore, the reassessment was not a change of opinion but a valid exercise of power u/s 147. The Court held the ITAT's finding on change of opinion as unsustainable. The ITAT's failure to address the revenue's appeal on the escaped income was noted. The decision favored the revenue.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
Join Channel
TaxTMI 
