Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
Diagnostic microcuvette classification follows sole-use analytical function, placing specialised disposable cuvettes with their analyser rather than g...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4884 
