Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
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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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