Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Reopening of assessment is time barred where the assessee filed a return and disclosed all material facts; audit objections that merely note absence of justification in the file do not constitute fresh information to initiate reassessment if the assessing officer already possessed the relevant documents. Consequently, under the pre 1 April 2021 scheme the extended six year period is unavailable and reassessment notices issued beyond four years from the end of the assessment year are invalid; the notice dated 31.03.2023 and subsequent proceedings are therefore barred by limitation.
Reopening of assessment is time barred where the assessee filed a return and disclosed all material facts; audit objections that merely note absence of justification in the file do not constitute fresh information to initiate reassessment if the assessing officer already possessed the relevant documents. Consequently, under the pre 1 April 2021 scheme the extended six year period is unavailable and reassessment notices issued beyond four years from the end of the assessment year are invalid; the notice dated 31.03.2023 and subsequent proceedings are therefore barred by limitation.
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