Residual food-preparation classification places fermented Nata De Coco outside fruit-jelly categories, changing its GST treatment across notified peri...
Settlement application eligibility requires a pending assessment when filed, preventing an extra prior-eligibility condition from blocking considerati...
Reassessment for unreturned property sales survives where transfer information, non-filing, and unsupported exemption claims establish a prima facie l...
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Validity of reassessment proceedings u/s 147, the requirement of fresh tangible material for reopening assessment, and the disallowance of expenditure incurred on DAP, production, and translation expenses. The court held that the reasons provided by the Assessing Officer (AO) failed to demonstrate the assessee's failure to disclose fully and truly, rendering the reassessment exercise nugatory. The court observed that the purported reasons only demonstrated a change of opinion, which cannot form the basis for reopening the assessment. The court also noted that even if the AO's argument of allowing expenses due to a mistake or without verification is accepted, the appropriate remedy would lie u/s 263. Consequently, the essential ingredient for reopening the assessment beyond four years was not satisfied, making the reassessment proceedings bad in law. Additionally, the court highlighted that the details regarding the expenses were placed before the AO in the previous assessment years, and the claim for deductibility was allowed, attaining finality. Since identical expenditure was claimed year after year without disallowance, the basis for "reasons to believe" did not survive anymore. The decision was in favor of the assessee.
Validity of reassessment proceedings u/s 147, the requirement of fresh tangible material for reopening assessment, and the disallowance of expenditure incurred on DAP, production, and translation expenses. The court held that the reasons provided by the Assessing Officer (AO) failed to demonstrate the assessee's failure to disclose fully and truly, rendering the reassessment exercise nugatory. The court observed that the purported reasons only demonstrated a change of opinion, which cannot form the basis for reopening the assessment. The court also noted that even if the AO's argument of allowing expenses due to a mistake or without verification is accepted, the appropriate remedy would lie u/s 263. Consequently, the essential ingredient for reopening the assessment beyond four years was not satisfied, making the reassessment proceedings bad in law. Additionally, the court highlighted that the details regarding the expenses were placed before the AO in the previous assessment years, and the claim for deductibility was allowed, attaining finality. Since identical expenditure was claimed year after year without disallowance, the basis for "reasons to believe" did not survive anymore. The decision was in favor of the assessee.
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