Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
