Prospective valuation amendment limits reassessment: unamended fair market value reference could not justify reopening based on a registered valuer's ...
Exemption for examination-related services rejected where recipients were commercial entities; suppression sustained extended limitation and penalties...
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The ITAT held the reassessment order u/s 147/143(3) void ab initio due to jurisdictional defects. The notice was dispatched on 01.04.2014, rendering it time-barred beyond the 4-year limitation period. The tribunal found the assessee had fully disclosed material facts during original assessment proceedings, and the AO had already scrutinized all relevant information. Relying on SC precedent in Kelvinator case, the tribunal emphasized that reopening assessment cannot be a mere change of opinion. The AO's attempt to review was deemed an abuse of power, with the tribunal ultimately deciding in favor of the assessee.
The ITAT held the reassessment order u/s 147/143(3) void ab initio due to jurisdictional defects. The notice was dispatched on 01.04.2014, rendering it time-barred beyond the 4-year limitation period. The tribunal found the assessee had fully disclosed material facts during original assessment proceedings, and the AO had already scrutinized all relevant information. Relying on SC precedent in Kelvinator case, the tribunal emphasized that reopening assessment cannot be a mere change of opinion. The AO's attempt to review was deemed an abuse of power, with the tribunal ultimately deciding in favor of the assessee.
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