Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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