Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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The HC held that the reopening of assessment beyond four years was without jurisdiction as the reasons did not disclose any material facts that the assessee failed to disclose during the original assessment proceedings. Merely reproducing the proviso's wordings does not satisfy the jurisdictional condition for reopening. The reasons recorded were based on the assessee's case records filed during the assessment, which is impermissible for reopening after four years under the first proviso to Section 147. The HC ruled in favor of the assessee.
The HC held that the reopening of assessment beyond four years was without jurisdiction as the reasons did not disclose any material facts that the assessee failed to disclose during the original assessment proceedings. Merely reproducing the proviso's wordings does not satisfy the jurisdictional condition for reopening. The reasons recorded were based on the assessee's case records filed during the assessment, which is impermissible for reopening after four years under the first proviso to Section 147. The HC ruled in favor of the assessee.
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