Form 26AS evidence requires successor-entity accounting verification after business transfer, while invoice-supported related-party advertising expend...
Money-laundering judgment timing requires awaiting the scheduled-offence decision despite continuation of the underlying trial where outcomes directly...
Accredited investor eligibility expands through securities-market exposure, while alternative investment fund disputes require prescribed resolution a...
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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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