Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
Validity of reopening of assessment on a non-searched person is examined, focusing on third-party reopening and the mandatory requirement of application of mind. The notice treating the assessee both as searched and non-searched is held to be cursory and devoid of application of mind, and the assessment references an unrelated search without establishing linkage to the search relied upon in the notice. The defective notice and consequent assessment are therefore regarded as resulting from casual drafting, and the challenge to the reopening on that ground is sustained.
Validity of reopening of assessment on a non-searched person is examined, focusing on third-party reopening and the mandatory requirement of application of mind. The notice treating the assessee both as searched and non-searched is held to be cursory and devoid of application of mind, and the assessment references an unrelated search without establishing linkage to the search relied upon in the notice. The defective notice and consequent assessment are therefore regarded as resulting from casual drafting, and the challenge to the reopening on that ground is sustained.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4821 
Join Channel 
