Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
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The High Court held that the reopening of assessment u/s 147 by the Assessing Officer (AO) was without jurisdiction and amounted to a mere change of opinion. The issue of unsecured loans availed by the petitioner from Phulchand Export Pvt. Ltd. was scrutinized during the regular assessment proceedings, and the AO was satisfied with the details provided by the petitioner. The mere fact that Phulchand Export Pvt. Ltd. incurred losses cannot be grounds to doubt the creditworthiness and genuineness of the unsecured loan. Once an issue is scrutinized during regular assessment, the same issue cannot be considered for reopening the assessment, as it would amount to a change of opinion. The impugned notice was held to be issued without jurisdiction, and the decision was in favor of the assessee.
The High Court held that the reopening of assessment u/s 147 by the Assessing Officer (AO) was without jurisdiction and amounted to a mere change of opinion. The issue of unsecured loans availed by the petitioner from Phulchand Export Pvt. Ltd. was scrutinized during the regular assessment proceedings, and the AO was satisfied with the details provided by the petitioner. The mere fact that Phulchand Export Pvt. Ltd. incurred losses cannot be grounds to doubt the creditworthiness and genuineness of the unsecured loan. Once an issue is scrutinized during regular assessment, the same issue cannot be considered for reopening the assessment, as it would amount to a change of opinion. The impugned notice was held to be issued without jurisdiction, and the decision was in favor of the assessee.
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