Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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.
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