Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Appointment of Registrars as adjudicating officers under Companies Act reallocates territorial jurisdiction and sets appeal route to Regional Director...
Composite supply of drilling services and site specific chemicals characterised as composite supply; prior advance rulings set aside, tax rate left op...
Reopening an assessment requires contemporaneous reasons to believe supported by tangible material and a live link to escapement of income; a mere recalculation of full value of consideration using lowest prevailing market value or a change of opinion is insufficient. The taxpayer had already provided stock valuation details and basis in response to queries under section 142(1), and the subsequent communications did not disclose fresh tangible material or a live link justifying reassessment under section 147. The impugned reopening notices were therefore held to lack jurisdiction and were quashed in favour of the assessee.
Reopening an assessment requires contemporaneous reasons to believe supported by tangible material and a live link to escapement of income; a mere recalculation of full value of consideration using lowest prevailing market value or a change of opinion is insufficient. The taxpayer had already provided stock valuation details and basis in response to queries under section 142(1), and the subsequent communications did not disclose fresh tangible material or a live link justifying reassessment under section 147. The impugned reopening notices were therefore held to lack jurisdiction and were quashed in favour of the assessee.
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