Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
Before invoking provisional attachment powers, authorities must form an objective opinion on tangible material demonstrating necessity to protect revenue; reliance on bank loans or hypothetical future demand is insufficient. Authorities must consider the assessee's history as a regular taxpayer when deciding on attachment. Provisional attachment is a draconian power and, consistent with principles of natural justice and applicable administrative guidance, the assessee should be afforded the opportunity to deposit a portion of the disputed demand as a minimum safeguard. The impugned attachment was set aside for lack of requisite formation of opinion and failure to permit the prescribed deposit mechanism, with a deposit direction issued.
Before invoking provisional attachment powers, authorities must form an objective opinion on tangible material demonstrating necessity to protect revenue; reliance on bank loans or hypothetical future demand is insufficient. Authorities must consider the assessee's history as a regular taxpayer when deciding on attachment. Provisional attachment is a draconian power and, consistent with principles of natural justice and applicable administrative guidance, the assessee should be afforded the opportunity to deposit a portion of the disputed demand as a minimum safeguard. The impugned attachment was set aside for lack of requisite formation of opinion and failure to permit the prescribed deposit mechanism, with a deposit direction issued.
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