Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
The case involves the validity of reopening of assessment u/s 147/148 based on reasons to believe, where the head of income was changed from business to income from other sources due to poor quality material in sub-contract execution. The Appellate Tribunal held that no fresh information was available to the Assessing Officer (AO) at the time of recording reasons for reopening, rendering the reassessment a mere change of opinion. The law requires reasons for reopening to be based on new information not previously considered. The Tribunal cited legal precedents to support this principle. The AO's reliance on post-survey inquiries by the same AO was deemed insufficient for reopening. The Tribunal found no basis for escapement of income without quantifying the alleged tax evasion. The assessment under section 147 was deemed illegal and quashed in favor of the assessee.
The case involves the validity of reopening of assessment u/s 147/148 based on reasons to believe, where the head of income was changed from business to income from other sources due to poor quality material in sub-contract execution. The Appellate Tribunal held that no fresh information was available to the Assessing Officer (AO) at the time of recording reasons for reopening, rendering the reassessment a mere change of opinion. The law requires reasons for reopening to be based on new information not previously considered. The Tribunal cited legal precedents to support this principle. The AO's reliance on post-survey inquiries by the same AO was deemed insufficient for reopening. The Tribunal found no basis for escapement of income without quantifying the alleged tax evasion. The assessment under section 147 was deemed illegal and quashed in favor of the assessee.
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