Tax authority's substitution of projected figures with actuals overturned; original acquisition valuation upheld; transfer pricing issues remitted for...
Beneficial owner held liable for differential customs duty; royalties added under Rule 10(1)(c); confiscation, penalties under s.111(m), s.114A, s.112...
HC upheld the validity of reassessment proceedings initiated u/s 147 against the assessee. It held that the AO had correctly formed a reason to believe that income had escaped assessment due to the assessee's failure to fully and truly disclose all material facts necessary for assessment, specifically the agreement with the Central Government required for claiming deduction u/s 42. Mere disclosure of the deduction claim in the audit report and return of income was held insufficient in the absence of the underlying agreement. Accepting the concurrent factual findings of the AO, CIT(A), and Tribunal, HC found no perversity warranting interference. The reassessment was held to be within limitation and legally sustainable. The appeal was dismissed and decided against the assessee.
HC upheld the validity of reassessment proceedings initiated u/s 147 against the assessee. It held that the AO had correctly formed a reason to believe that income had escaped assessment due to the assessee's failure to fully and truly disclose all material facts necessary for assessment, specifically the agreement with the Central Government required for claiming deduction u/s 42. Mere disclosure of the deduction claim in the audit report and return of income was held insufficient in the absence of the underlying agreement. Accepting the concurrent factual findings of the AO, CIT(A), and Tribunal, HC found no perversity warranting interference. The reassessment was held to be within limitation and legally sustainable. The appeal was dismissed and decided against the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
