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 Appellate Tribunal considered the validity of the reopening of assessment u/s 147 beyond four years. The assessment was based on notes to accounts for AY 2009-10. The Tribunal noted that the assessee had fully disclosed details during the original assessment u/s 143(3), and the assessing officer verified these details. The Tribunal emphasized that for reopening after four years, there must be a failure to disclose all material facts. The Supreme Court held that the AO can reassess based on new material only. In this case, the assessing officer made additions based on materials already verified in the original assessment u/s 143(3) without any new basis for reopening. The Tribunal allowed the assessee's appeal.
The Appellate Tribunal considered the validity of the reopening of assessment u/s 147 beyond four years. The assessment was based on notes to accounts for AY 2009-10. The Tribunal noted that the assessee had fully disclosed details during the original assessment u/s 143(3), and the assessing officer verified these details. The Tribunal emphasized that for reopening after four years, there must be a failure to disclose all material facts. The Supreme Court held that the AO can reassess based on new material only. In this case, the assessing officer made additions based on materials already verified in the original assessment u/s 143(3) without any new basis for reopening. The Tribunal allowed the assessee's appeal.
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