Retrospective cancellation of charitable registration under section 12AB(4) was unsustainable; related-party benefit allegations did not prove nongenu...
Merger control notice and disclosure rules: Supreme Court limits penalties, rejects reopening of approved combination, and sets aside adverse findings...
Reassessment under Section 148 requires prima facie material showing a live link between the seized material and alleged income escaping assessment. The High Court held that vague, non-specific loose papers referring only to survey numbers, a rate and a third person's name, without the assessee's name or any nexus to her, could not justify reopening. The expressions "relates to" and "pertains to" in Explanation 2 to Section 148 cannot be applied in isolation; the Revenue must assess the material against surrounding circumstances and record prima facie relevancy. As the information lacked that connection, the notice and consequential reopening were quashed.
Reassessment under Section 148 requires prima facie material showing a live link between the seized material and alleged income escaping assessment. The High Court held that vague, non-specific loose papers referring only to survey numbers, a rate and a third person's name, without the assessee's name or any nexus to her, could not justify reopening. The expressions "relates to" and "pertains to" in Explanation 2 to Section 148 cannot be applied in isolation; the Revenue must assess the material against surrounding circumstances and record prima facie relevancy. As the information lacked that connection, the notice and consequential reopening were quashed.
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