Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
Administrative fraud classification suspension does not halt independent criminal investigation or warrant-based searches into alleged economic offenc...
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The High Court addressed the issue of reopening assessment u/s 147 of the Income Tax Act. The case involved the alleged absence of a "reason to believe" and a "live link" between information and belief. The assessment was reopened based on information uploaded by the ADIT (Inv) on the Income Tax Department's portal, designated as "High Risk Transaction" for 2016-17. The petitioner had declared the loss in the return for 2017-18, which was accepted by the AO. The Court emphasized that reopening required a valid reason to believe income had escaped assessment, not merely a change of opinion. The Court found the existing Section 147 requirements were not met, as no credible information supported the reopening. The notice u/s 148 and the subsequent order were quashed in favor of the assessee.
The High Court addressed the issue of reopening assessment u/s 147 of the Income Tax Act. The case involved the alleged absence of a "reason to believe" and a "live link" between information and belief. The assessment was reopened based on information uploaded by the ADIT (Inv) on the Income Tax Department's portal, designated as "High Risk Transaction" for 2016-17. The petitioner had declared the loss in the return for 2017-18, which was accepted by the AO. The Court emphasized that reopening required a valid reason to believe income had escaped assessment, not merely a change of opinion. The Court found the existing Section 147 requirements were not met, as no credible information supported the reopening. The notice u/s 148 and the subsequent order were quashed in favor of the assessee.
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