Opportunity to respond to jurisdictional reports is mandatory before customs settlement duty enhancement; connected applications require consistent ad...
Specific customs headings for scaffolding components prevail over general classification, invalidating misclassification proceedings and enabling with...
Liquidator appointment under Section 34 requires consideration of creditor recommendations, valid professional authorisation, and preservation of vali...
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The Delhi High Court examined the validity of reassessment proceedings u/s 147 after a four-year lapse. The court emphasized the requirement of "reasons to believe" for reopening assessments. It noted that the AO lacked specific grounds for reassessment, resembling past cases. The CIT(A) upheld reassessment based on a revenue audit report, but failed to establish a direct link between reasons and belief u/s 147. The court found the initiation of reassessment after four years without fresh material as legally unsound, rejecting the Revenue's case. The decision favored the assessee, emphasizing the need for concrete grounds for reassessment within the statutory period.
The Delhi High Court examined the validity of reassessment proceedings u/s 147 after a four-year lapse. The court emphasized the requirement of "reasons to believe" for reopening assessments. It noted that the AO lacked specific grounds for reassessment, resembling past cases. The CIT(A) upheld reassessment based on a revenue audit report, but failed to establish a direct link between reasons and belief u/s 147. The court found the initiation of reassessment after four years without fresh material as legally unsound, rejecting the Revenue's case. The decision favored the assessee, emphasizing the need for concrete grounds for reassessment within the statutory period.
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