Transaction value rejection requires reliable corroboration; refundable VAT is excluded and temporary registration does not defeat new-vehicle exempti...
Appellate jurisdiction remains available where a wrist-worn gold ornament cannot conclusively be characterised as imported baggage at the preliminary ...
Written complaint requirement bars cognizance on police reports for securities offences, while unsupported breach of trust and cheating allegations fa...
Risk-based postal import clearance standardises electronic assessment, document requests, duty realisation and delivery controls at Foreign Post Offic...
Customs Cargo Service Provider appointment extends custodianship to additional terminal land, subject to cargo-control, security and licence condition...
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The High Court held that the Assessing Officer cannot reopen the assessment u/s 147 merely based on a change of opinion. The assessee had fully and truly disclosed all material facts during the original assessment proceedings. The reasons recorded by the Assessing Officer for reopening the assessment did not reveal any fresh tangible material, indicating that the belief was formed based on a mere verification of records, resulting in a change of opinion. The Court emphasized the conceptual difference between the power to review and the power to reassess, stating that while the Assessing Officer lacks the power to review, reassessment must be based on fulfilling certain preconditions. Removing the concept of "change of opinion" would allow the Assessing Officer to review assessments under the guise of reopening, leading to potential abuse of power. The Court ruled in favor of the assessee, upholding the principle that a mere change of opinion cannot justify reassessment proceedings.
The High Court held that the Assessing Officer cannot reopen the assessment u/s 147 merely based on a change of opinion. The assessee had fully and truly disclosed all material facts during the original assessment proceedings. The reasons recorded by the Assessing Officer for reopening the assessment did not reveal any fresh tangible material, indicating that the belief was formed based on a mere verification of records, resulting in a change of opinion. The Court emphasized the conceptual difference between the power to review and the power to reassess, stating that while the Assessing Officer lacks the power to review, reassessment must be based on fulfilling certain preconditions. Removing the concept of "change of opinion" would allow the Assessing Officer to review assessments under the guise of reopening, leading to potential abuse of power. The Court ruled in favor of the assessee, upholding the principle that a mere change of opinion cannot justify reassessment proceedings.
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