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Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
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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