Development rights transfers treated as immovable property, while construction abatement applies and repeated non-payment permits extended service-tax...
Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
Reassessment based on the same interest income and TDS mismatch material already examined in final appellate proceedings was held to be an impermissible change of opinion. The sanction note disclosed no fresh tangible information, new ground, or subsequent material suggesting escapement of income, so reopening under Section 148 amounted to a collateral attack on a concluded determination. On that basis, the HC found the assumption of jurisdiction unsustainable and quashed the notice, sanction note, and consequential proceedings.
Reassessment based on the same interest income and TDS mismatch material already examined in final appellate proceedings was held to be an impermissible change of opinion. The sanction note disclosed no fresh tangible information, new ground, or subsequent material suggesting escapement of income, so reopening under Section 148 amounted to a collateral attack on a concluded determination. On that basis, the HC found the assumption of jurisdiction unsustainable and quashed the notice, sanction note, and consequential proceedings.
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