Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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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