Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
Reopening of assessment was challenged because the stated grounds-an alleged clerical mistake in inventory computations and unexplained cash deposits-no longer survive: the inventory-based addition has since been deleted by the ITAT and the Revenue does not dispute that deletion, and the cash deposits were specifically queried and satisfactorily explained with the cash book produced during original scrutiny, leading the AO then to make no addition. The article concludes that reassessment here amounts to a mere change of opinion and is therefore not justified.
Reopening of assessment was challenged because the stated grounds-an alleged clerical mistake in inventory computations and unexplained cash deposits-no longer survive: the inventory-based addition has since been deleted by the ITAT and the Revenue does not dispute that deletion, and the cash deposits were specifically queried and satisfactorily explained with the cash book produced during original scrutiny, leading the AO then to make no addition. The article concludes that reassessment here amounts to a mere change of opinion and is therefore not justified.
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