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Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
Cross-examination rights and corroborated evidence limit customs penalties for misdeclaration in genuine import transactions involving documented clea...
Tariff classification of vehicle gear components follows the specific gearing entry, displacing motor-vehicle parts classification and related liabili...
Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Reopening of assessment u/s 147 was challenged on the ground of mere change of opinion. The assessee had filed return claiming deduction u/s 80IC and furnished all relevant details during original assessment proceedings u/s 143(3). The Assessing Officer, after examining the details, passed the assessment order accepting the return. Subsequently, notice u/s 148 was issued for reopening assessment on the ground that the undertaking availing deduction u/s 80IC was merged with the assessee company, rendering it ineligible for such deduction u/s 80IC(12) read with Section 80IA(12A). The High Court held that since all material facts were disclosed and examined during original assessment, reopening would amount to mere change of opinion, which is impermissible. Accordingly, the reopening notice u/s 148 was quashed.
Reopening of assessment u/s 147 was challenged on the ground of mere change of opinion. The assessee had filed return claiming deduction u/s 80IC and furnished all relevant details during original assessment proceedings u/s 143(3). The Assessing Officer, after examining the details, passed the assessment order accepting the return. Subsequently, notice u/s 148 was issued for reopening assessment on the ground that the undertaking availing deduction u/s 80IC was merged with the assessee company, rendering it ineligible for such deduction u/s 80IC(12) read with Section 80IA(12A). The High Court held that since all material facts were disclosed and examined during original assessment, reopening would amount to mere change of opinion, which is impermissible. Accordingly, the reopening notice u/s 148 was quashed.
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