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...
Reopening of assessment under section 147 was quashed because the Assessing Officer lacked tangible information to form a belief that income had escaped assessment; the Tribunal found the AO had misread binding precedent treating amounts under Section 28 of the Land Acquisition Act as accretions to land value (compensation) rather than ordinary 'income from other sources'. The Tribunal also upheld the sanction notation by the Joint Commissioner as valid despite concise wording, finding no absence of application of mind. Result: sanction valid but reopening invalid; appeal allowed.
Reopening of assessment under section 147 was quashed because the Assessing Officer lacked tangible information to form a belief that income had escaped assessment; the Tribunal found the AO had misread binding precedent treating amounts under Section 28 of the Land Acquisition Act as accretions to land value (compensation) rather than ordinary 'income from other sources'. The Tribunal also upheld the sanction notation by the Joint Commissioner as valid despite concise wording, finding no absence of application of mind. Result: sanction valid but reopening invalid; appeal allowed.
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