Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
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...
For reopening beyond three years, the statutory threshold under section 149(1)(b) must be met by material showing escaped income of Rs. 50 lakhs or more. The Tribunal held that the reopening was initiated on incorrect or non-existing portal information, because the assessment ultimately treated only Rs. 17,17,597 as unexplained after verification and explanation by the assessee. As the case did not satisfy the extended-limitation condition, it fell within section 149(1)(a) and the notice under section 148 issued beyond three years was invalid. The consequential reassessment order under section 147 read with section 144B was quashed as void ab initio.
For reopening beyond three years, the statutory threshold under section 149(1)(b) must be met by material showing escaped income of Rs. 50 lakhs or more. The Tribunal held that the reopening was initiated on incorrect or non-existing portal information, because the assessment ultimately treated only Rs. 17,17,597 as unexplained after verification and explanation by the assessee. As the case did not satisfy the extended-limitation condition, it fell within section 149(1)(a) and the notice under section 148 issued beyond three years was invalid. The consequential reassessment order under section 147 read with section 144B was quashed as void ab initio.
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