Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
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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