Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Page of 4805
Press 'Enter' after typing page number.
1201 to 1220 of 96100 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The assessment order was challenged on the grounds of validity of reopening after four years, based on a change of opinion and borrowed satisfaction. The assessee contended that there were no purchase or sale transactions on the National Spot Exchange Limited (NSEL) during the relevant assessment year. The statutory auditor's report u/s 142A confirmed no stock pertaining to NSEL transactions. However, the Assessing Officer reopened the assessment solely based on outstanding dues payable by the assessee to NSEL from earlier years, without considering the available material and audit report. The High Court held that the reopening notice was issued without application of mind, amounting to a change of opinion and borrowed satisfaction, as the entire issue was scrutinized during the regular assessment. The assessee had made full and true disclosures, and the reasons recorded for reopening were without jurisdiction on the face of the material available on record. Consequently, the assessee's appeal was allowed.
The assessment order was challenged on the grounds of validity of reopening after four years, based on a change of opinion and borrowed satisfaction. The assessee contended that there were no purchase or sale transactions on the National Spot Exchange Limited (NSEL) during the relevant assessment year. The statutory auditor's report u/s 142A confirmed no stock pertaining to NSEL transactions. However, the Assessing Officer reopened the assessment solely based on outstanding dues payable by the assessee to NSEL from earlier years, without considering the available material and audit report. The High Court held that the reopening notice was issued without application of mind, amounting to a change of opinion and borrowed satisfaction, as the entire issue was scrutinized during the regular assessment. The assessee had made full and true disclosures, and the reasons recorded for reopening were without jurisdiction on the face of the material available on record. Consequently, the assessee's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
