Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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The HC quashed reassessment proceedings under s.147 initiated after four years on multiple grounds. The proceedings lacked jurisdiction as the reasons for reopening failed to specify any non-disclosure of material facts by the assessee as required by the first proviso to s.147. The Court noted discrepancies between reasons in the draft assessment order and those annexed to the reply affidavit. Additionally, the "guarantee fees" issue was already pending before the Tribunal, invoking the third proviso to s.147 which bars reassessment on matters under appellate consideration. The Court emphasized that since the issue had been examined and added in the original assessment, there was no income that had "escaped assessment," rendering the proceedings jurisdictionally defective.
The HC quashed reassessment proceedings under s.147 initiated after four years on multiple grounds. The proceedings lacked jurisdiction as the reasons for reopening failed to specify any non-disclosure of material facts by the assessee as required by the first proviso to s.147. The Court noted discrepancies between reasons in the draft assessment order and those annexed to the reply affidavit. Additionally, the "guarantee fees" issue was already pending before the Tribunal, invoking the third proviso to s.147 which bars reassessment on matters under appellate consideration. The Court emphasized that since the issue had been examined and added in the original assessment, there was no income that had "escaped assessment," rendering the proceedings jurisdictionally defective.
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