Handicraft job work receives concessional GST only for registered principals and predominantly handmade goods; commercial resin articles remain taxabl...
Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination b...
Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
Reopening beyond four years was invalid because the recorded reasons showed reliance on material already examined in the original scrutiny, not on any fresh tangible material. The Tribunal noted that the AO had specifically called for and reviewed purchase bills, ledgers, bank statements, export details and related records before completing the assessment without addition. In these circumstances, there was no failure by the assessee to disclose fully and truly all material facts, and reopening on the same material amounted to a change of opinion. The jurisdictional condition under the proviso to section 147 was not met, so the reassessment proceedings were held bad in law and quashed.
Reopening beyond four years was invalid because the recorded reasons showed reliance on material already examined in the original scrutiny, not on any fresh tangible material. The Tribunal noted that the AO had specifically called for and reviewed purchase bills, ledgers, bank statements, export details and related records before completing the assessment without addition. In these circumstances, there was no failure by the assessee to disclose fully and truly all material facts, and reopening on the same material amounted to a change of opinion. The jurisdictional condition under the proviso to section 147 was not met, so the reassessment proceedings were held bad in law and quashed.
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