Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
HC dismissed Revenue's appeal challenging reopening of assessment u/s 147. The court found no valid grounds for reassessment as there was no failure by assessee to disclose material facts fully and truly during original assessment. The reopening attempt by successor AO on previously decided issues amounted to improper exercise of revisionary powers. The court held that mere change of opinion cannot justify reopening beyond 4-year limitation period without new material facts. The Revenue's attempt to reopen assessment based on different interpretation of same facts was deemed invalid, as original assessment decision had considered and accepted assessee's claims. Decision affirmed CIT(A)'s order quashing the reassessment notice.
HC dismissed Revenue's appeal challenging reopening of assessment u/s 147. The court found no valid grounds for reassessment as there was no failure by assessee to disclose material facts fully and truly during original assessment. The reopening attempt by successor AO on previously decided issues amounted to improper exercise of revisionary powers. The court held that mere change of opinion cannot justify reopening beyond 4-year limitation period without new material facts. The Revenue's attempt to reopen assessment based on different interpretation of same facts was deemed invalid, as original assessment decision had considered and accepted assessee's claims. Decision affirmed CIT(A)'s order quashing the reassessment notice.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
