Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
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...
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The HC invalidated the reassessment proceedings under Section 147, finding no tangible material indicating escaped income. The court determined that the Assessing Officer merely reconsidered the same material that had already undergone scrutiny during the original assessment, where Section 10A deductions were already reduced from the claimed amount. The reasons furnished for reopening failed to demonstrate any failure by the assessee to disclose true and full material facts-a prerequisite under Section 147. The court concluded that the reassessment constituted an impermissible change of opinion rather than discovery of new information, as no new material or undeclared income was identified that wasn't available during the original assessment process.
The HC invalidated the reassessment proceedings under Section 147, finding no tangible material indicating escaped income. The court determined that the Assessing Officer merely reconsidered the same material that had already undergone scrutiny during the original assessment, where Section 10A deductions were already reduced from the claimed amount. The reasons furnished for reopening failed to demonstrate any failure by the assessee to disclose true and full material facts-a prerequisite under Section 147. The court concluded that the reassessment constituted an impermissible change of opinion rather than discovery of new information, as no new material or undeclared income was identified that wasn't available during the original assessment process.
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