Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
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The case pertains to the reopening of assessment u/s 147 of the Income Tax Act. The key points are: The department had already raised queries regarding the accumulation and utilization of funds for different purposes during the original assessment proceedings in 2011. The assessee had provided explanations, which were accepted by the Assessing Officer (AO) at that time. The notice for reopening assessment in 2016 was based on the same issue, which amounts to a mere change of opinion by the AO, not permissible for reopening under the 6-year limitation period. The court relied on precedents like Kelvinator of India and Marico Limited to conclude that once an issue is raised and responded to during assessment, the AO is deemed to have accepted the assessee's explanation if not dealt with in the order. Therefore, the reopening notice was held invalid, being a case of change of opinion, and the assessee's appeal was allowed.
The case pertains to the reopening of assessment u/s 147 of the Income Tax Act. The key points are: The department had already raised queries regarding the accumulation and utilization of funds for different purposes during the original assessment proceedings in 2011. The assessee had provided explanations, which were accepted by the Assessing Officer (AO) at that time. The notice for reopening assessment in 2016 was based on the same issue, which amounts to a mere change of opinion by the AO, not permissible for reopening under the 6-year limitation period. The court relied on precedents like Kelvinator of India and Marico Limited to conclude that once an issue is raised and responded to during assessment, the AO is deemed to have accepted the assessee's explanation if not dealt with in the order. Therefore, the reopening notice was held invalid, being a case of change of opinion, and the assessee's appeal was allowed.
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