Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
HC allowed the writ petition challenging reassessment proceedings under Section 147. The court found that the Assessing Officer (AO) lacked valid grounds for reopening the assessment, as the taxpayer had made full and true disclosure during the original proceedings. The AO failed to demonstrate independent application of mind or identify any fresh information justifying reassessment. The court observed that the AO was cognizant of all relevant facts during the initial assessment and merely relied on a subsequent year's communication without substantive evidence of concealment or incorrect information. Consequently, the reassessment order was quashed as procedurally invalid and without reasonable basis.
HC allowed the writ petition challenging reassessment proceedings under Section 147. The court found that the Assessing Officer (AO) lacked valid grounds for reopening the assessment, as the taxpayer had made full and true disclosure during the original proceedings. The AO failed to demonstrate independent application of mind or identify any fresh information justifying reassessment. The court observed that the AO was cognizant of all relevant facts during the initial assessment and merely relied on a subsequent year's communication without substantive evidence of concealment or incorrect information. Consequently, the reassessment order was quashed as procedurally invalid and without reasonable basis.
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