Tariff classification determines GST schedule and rate; beverages in Schedule III attract the higher rate, tea extracts and syrups in Schedule I attra...
Fraudulent trading requires cogent evidence of intent to defraud; ordinary-course payments protected, except post-insolvency withdrawals must be resto...
Religious purpose exclusion versus charitable purpose: non overriding religious objects do not attract Explanation 3, registration directed under sect...
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 4811 
Join Channel 
