Steel-timber construction shuttering/formwork tariff classification dispute: essential character held steel, classified as shuttering under Heading 73...
Family-linked property purchases using fabricated loan agreements and benami-style arrangements held to be crime proceeds; attachment upheld, appeal d...
Charitable tree plantation and maintenance for environmental preservation treated as "charitable activity", exempt from GST under Notification 12/2017...
Reopening under s.147 based on alleged cash purchases reflected in TAS was challenged as an impermissible change of opinion after the AO had earlier dropped inquiry for want of evidence. The court held that "opinion" requires formation on available material; mere availability of transaction entries without corroborative data linking the assessee to the alleged counterparty did not amount to an opinion, particularly when the assessee denied any relationship, making verification impossible. Since the impugned s.148 notice relied on new, tangible material establishing the linkage, no jurisdictional error was shown and the reopening was upheld. - HC
Reopening under s.147 based on alleged cash purchases reflected in TAS was challenged as an impermissible change of opinion after the AO had earlier dropped inquiry for want of evidence. The court held that "opinion" requires formation on available material; mere availability of transaction entries without corroborative data linking the assessee to the alleged counterparty did not amount to an opinion, particularly when the assessee denied any relationship, making verification impossible. Since the impugned s.148 notice relied on new, tangible material establishing the linkage, no jurisdictional error was shown and the reopening was upheld. - HC
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