Retrospective cancellation of charitable registration under section 12AB(4) was unsustainable; related-party benefit allegations did not prove nongenu...
Merger control notice and disclosure rules: Supreme Court limits penalties, rejects reopening of approved combination, and sets aside adverse findings...
HC held that the AO's reassessment notice under Section 147 was invalid. The AO mechanically recorded reasons based on third-party information without providing substantive evidence directly linking the petitioner to any undisclosed income. The court found no material connection between the survey operation and the petitioner's transactions. The AO's refusal to disclose confidential information to the assessee violated procedural fairness, rendering the reopening of assessment arbitrary and illegal. Consequently, the court quashed the reassessment notice, deciding in favor of the assessee and emphasizing the need for concrete, specific reasons when initiating reassessment proceedings.
HC held that the AO's reassessment notice under Section 147 was invalid. The AO mechanically recorded reasons based on third-party information without providing substantive evidence directly linking the petitioner to any undisclosed income. The court found no material connection between the survey operation and the petitioner's transactions. The AO's refusal to disclose confidential information to the assessee violated procedural fairness, rendering the reopening of assessment arbitrary and illegal. Consequently, the court quashed the reassessment notice, deciding in favor of the assessee and emphasizing the need for concrete, specific reasons when initiating reassessment proceedings.
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