Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Page of 4814
Press 'Enter' after typing page number.
5161 to 5180 of 96262 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
