Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Section 147/148 proceedings can only be initiated based on the original reasons recorded for forming the opinion of escapement of income. The Assessing Officer cannot deviate, supplement or supplant those reasons subsequently. Explanation 3 to Section 147 does not empower the Assessing Officer to improve upon or change the original reasons. The validity of reassessment must be judged from the standpoint of the initial reasons recorded. Once reassessment is validly initiated, Explanation 3 allows the Assessing Officer to consider other issues during reassessment proceedings, subject to the requirement of valid initiation. The High Court quashed the impugned notices and orders, deciding in favor of the assessee.
Section 147/148 proceedings can only be initiated based on the original reasons recorded for forming the opinion of escapement of income. The Assessing Officer cannot deviate, supplement or supplant those reasons subsequently. Explanation 3 to Section 147 does not empower the Assessing Officer to improve upon or change the original reasons. The validity of reassessment must be judged from the standpoint of the initial reasons recorded. Once reassessment is validly initiated, Explanation 3 allows the Assessing Officer to consider other issues during reassessment proceedings, subject to the requirement of valid initiation. The High Court quashed the impugned notices and orders, deciding in favor of the assessee.
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