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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...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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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 reassessment initiated after the four-year period was invalid insofar as it rested solely on a change of opinion and not on tangible material demonstrating escapement of income. The court observed that once the appellant had discharged the duty to disclose material facts and an assessment was completed under s.143(3) following notices and inquiries under ss.142 and 143(2), the Assessing Officer lacked jurisdiction to reopen the assessment absent concealment or false declaration. Finding no evidence of nondisclosure or concealment, the HC answered the legal question in favour of the appellant and set aside the impugned reassessment orders, obviating the need to adjudicate the s.80-IB/80HHC deduction issues.
HC held that reassessment initiated after the four-year period was invalid insofar as it rested solely on a change of opinion and not on tangible material demonstrating escapement of income. The court observed that once the appellant had discharged the duty to disclose material facts and an assessment was completed under s.143(3) following notices and inquiries under ss.142 and 143(2), the Assessing Officer lacked jurisdiction to reopen the assessment absent concealment or false declaration. Finding no evidence of nondisclosure or concealment, the HC answered the legal question in favour of the appellant and set aside the impugned reassessment orders, obviating the need to adjudicate the s.80-IB/80HHC deduction issues.
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