Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
The HC held that the Assessing Officer could not reopen the assessment for AY 2013-14 merely relying on information from the insight portal without forming an independent opinion based on the assessee's records. The assessee had disclosed and offered to tax the loss from F&O transactions, which was scrutinized and accepted during regular assessment. Reopening on the same issue amounts to a change of opinion, which is impermissible. The reopening lacked tangible material and application of mind, rendering it invalid. The Court decided in favor of the assessee.
The HC held that the Assessing Officer could not reopen the assessment for AY 2013-14 merely relying on information from the insight portal without forming an independent opinion based on the assessee's records. The assessee had disclosed and offered to tax the loss from F&O transactions, which was scrutinized and accepted during regular assessment. Reopening on the same issue amounts to a change of opinion, which is impermissible. The reopening lacked tangible material and application of mind, rendering it invalid. The Court decided in favor of the assessee.
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