Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
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.
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