Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
Reopening of assessment under section 147/148 was contested where notices issued beyond four years relied principally on audit party or internal audit opinions and documents. The article explains the legal principle that an assessing officer must have his own information and form subjective satisfaction - mere reliance on audit reports or internal notes amounts to change of opinion and cannot sustain reassessment. It cites precedent that audit opinions are not 'information' per se and that reopening on identical materials is impermissible, resulting in decisions favouring the assessee where the AO lacked independent application of mind and subjective satisfaction.
Reopening of assessment under section 147/148 was contested where notices issued beyond four years relied principally on audit party or internal audit opinions and documents. The article explains the legal principle that an assessing officer must have his own information and form subjective satisfaction - mere reliance on audit reports or internal notes amounts to change of opinion and cannot sustain reassessment. It cites precedent that audit opinions are not 'information' per se and that reopening on identical materials is impermissible, resulting in decisions favouring the assessee where the AO lacked independent application of mind and subjective satisfaction.
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