Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
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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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