Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
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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