Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
Customs-controlled container movement now extends to DP World facilities, subject to segregation, inspections, reconciliation, and EXIM cargo priority...
Section 147 allows reopening of assessments in exceptional cases where the Assessing Officer has reason to believe income has escaped assessment. Concluded assessments should not be interfered with lightly. If the reopening ground cannot be sustained, there is little rationale for expanding reassessment proceedings. A strict interpretation of Section 147 is warranted given the nature of unsettling concluded assessments. Courts have held reassessment is confined to issues forming the reasons for reopening. Explanation 3 to Section 147 clarifies the AO can assess other issues noticed subsequently but does not override Section 147's plain language. The AO cannot assess other incomes where no addition is made on the reopening reasons. No substantial question of law arises.
Section 147 allows reopening of assessments in exceptional cases where the Assessing Officer has reason to believe income has escaped assessment. Concluded assessments should not be interfered with lightly. If the reopening ground cannot be sustained, there is little rationale for expanding reassessment proceedings. A strict interpretation of Section 147 is warranted given the nature of unsettling concluded assessments. Courts have held reassessment is confined to issues forming the reasons for reopening. Explanation 3 to Section 147 clarifies the AO can assess other issues noticed subsequently but does not override Section 147's plain language. The AO cannot assess other incomes where no addition is made on the reopening reasons. No substantial question of law arises.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
