Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Reopening of assessment u/s 147 was done solely for the purpose of verification of the source of purchase of property, which is not a valid reason as per settled judicial precedents. The Bombay High Court in Nivi Trading Ltd. v. Union of India has categorically held that reassessment u/s 147 cannot be done solely for verification purposes. Since reopening was done only for verification of source of investment in property, as evident from the reasons recorded by the Assessing Officer, relying on the judicial propositions that reopening cannot be done for verification, the reopening of assessment is held invalid and unjustified, and consequently, the assessment order does not survive. The appeal is allowed on this ground.
Reopening of assessment u/s 147 was done solely for the purpose of verification of the source of purchase of property, which is not a valid reason as per settled judicial precedents. The Bombay High Court in Nivi Trading Ltd. v. Union of India has categorically held that reassessment u/s 147 cannot be done solely for verification purposes. Since reopening was done only for verification of source of investment in property, as evident from the reasons recorded by the Assessing Officer, relying on the judicial propositions that reopening cannot be done for verification, the reopening of assessment is held invalid and unjustified, and consequently, the assessment order does not survive. The appeal is allowed on this ground.
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