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Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
HC held that reassessment notice issued beyond four years could not stand unless the proviso to Section 147 was satisfied. Because the recorded reasons did not allege failure by the assessee to make a full and true disclosure, and the material relied on was already before the AO in the original scrutiny assessment, the jurisdictional precondition for reopening was absent. The Court also held that reopening on the basis of the same material was a mere change of opinion, which cannot justify reassessment. The reassessment under Section 147 was therefore without jurisdiction and was rightly set aside; the Revenue's appeal was dismissed.
HC held that reassessment notice issued beyond four years could not stand unless the proviso to Section 147 was satisfied. Because the recorded reasons did not allege failure by the assessee to make a full and true disclosure, and the material relied on was already before the AO in the original scrutiny assessment, the jurisdictional precondition for reopening was absent. The Court also held that reopening on the basis of the same material was a mere change of opinion, which cannot justify reassessment. The reassessment under Section 147 was therefore without jurisdiction and was rightly set aside; the Revenue's appeal was dismissed.
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