Form 26AS evidence requires successor-entity accounting verification after business transfer, while invoice-supported related-party advertising expend...
Money-laundering judgment timing requires awaiting the scheduled-offence decision despite continuation of the underlying trial where outcomes directly...
Accredited investor eligibility expands through securities-market exposure, while alternative investment fund disputes require prescribed resolution a...
Customs Assessment Portal centralises classification and valuation guidance to support consistent, transparent and informed compliance across stakehol...
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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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