Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Reopening of assessment u/s 147 was not valid as the Revenue Audit Report merely pointed out discrepancy in computation method and opined on applicability of Section 50C, which is an interpretation of law and not 'information' required for reopening. The Assessing Officer's reasons recorded for reopening showed lack of reason to believe income escaped assessment, being mere reason to suspect based on change of opinion. Section 50C was held inapplicable to sale after conversion of capital asset into stock-in-trade, following precedents. The appeal was allowed in favor of the assessee.
Reopening of assessment u/s 147 was not valid as the Revenue Audit Report merely pointed out discrepancy in computation method and opined on applicability of Section 50C, which is an interpretation of law and not 'information' required for reopening. The Assessing Officer's reasons recorded for reopening showed lack of reason to believe income escaped assessment, being mere reason to suspect based on change of opinion. Section 50C was held inapplicable to sale after conversion of capital asset into stock-in-trade, following precedents. The appeal was allowed in favor of the assessee.
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