Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
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...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
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 quashed reassessment notice under Section 148 for Assessment Year 2016-17, ruling that revenue lacked valid "reason to believe" income escaped assessment under Section 147. Court held that identical grounds were previously examined during original scrutiny assessment completed on 24.12.2018. Since assessing officer possessed all necessary information regarding the disputed property during original assessment proceedings, the reopening constituted impermissible "change of opinion" rather than discovery of escaped income. Applying Kelvinator precedent, HC determined revenue cannot reassess based on mere reconsideration of previously available facts. The reassessment proceedings were deemed jurisdictionally invalid as they arose solely from revenue's altered perspective on same material already scrutinized. Petition allowed, notice set aside in assessee's favour.
HC quashed reassessment notice under Section 148 for Assessment Year 2016-17, ruling that revenue lacked valid "reason to believe" income escaped assessment under Section 147. Court held that identical grounds were previously examined during original scrutiny assessment completed on 24.12.2018. Since assessing officer possessed all necessary information regarding the disputed property during original assessment proceedings, the reopening constituted impermissible "change of opinion" rather than discovery of escaped income. Applying Kelvinator precedent, HC determined revenue cannot reassess based on mere reconsideration of previously available facts. The reassessment proceedings were deemed jurisdictionally invalid as they arose solely from revenue's altered perspective on same material already scrutinized. Petition allowed, notice set aside in assessee's favour.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
