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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
HC held that the Assessing Officer could not reopen the assessment merely on a change of opinion. The court found that the petitioner had already disclosed all relevant facts during the original assessment, including TDS details and deductions under section 80IC. The reopening of assessment was deemed improper as it did not reveal any new information constituting income escapement. The court emphasized that reassessment is not equivalent to reviewing the original assessment order. The procedural provisions and amendments to sections 147 and 148 did not alter the fundamental principle against reopening assessments based solely on a different interpretation of existing information. Judgment was decided in favor of the assessee.
HC held that the Assessing Officer could not reopen the assessment merely on a change of opinion. The court found that the petitioner had already disclosed all relevant facts during the original assessment, including TDS details and deductions under section 80IC. The reopening of assessment was deemed improper as it did not reveal any new information constituting income escapement. The court emphasized that reassessment is not equivalent to reviewing the original assessment order. The procedural provisions and amendments to sections 147 and 148 did not alter the fundamental principle against reopening assessments based solely on a different interpretation of existing information. Judgment was decided in favor of the assessee.
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