Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
The HC quashed reassessment initiated beyond four years from the end of the assessment year because it was based only on material already on record and showed no new tangible material. As the original assessment had been completed under Section 143(3), the first proviso to Section 147 required the Revenue to show that escaped income arose from the assessee's failure to disclose fully and truly all material facts. The recorded reasons contained only a bald assertion and did not identify any such failure. Reopening on the same material after the claim had already been examined was an impermissible change of opinion, so the notice under Section 148, the orders rejecting objections, and all consequential proceedings were set aside.
The HC quashed reassessment initiated beyond four years from the end of the assessment year because it was based only on material already on record and showed no new tangible material. As the original assessment had been completed under Section 143(3), the first proviso to Section 147 required the Revenue to show that escaped income arose from the assessee's failure to disclose fully and truly all material facts. The recorded reasons contained only a bald assertion and did not identify any such failure. Reopening on the same material after the claim had already been examined was an impermissible change of opinion, so the notice under Section 148, the orders rejecting objections, and all consequential proceedings were set aside.
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