Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
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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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