Belated Form 10B filing during Covid-19 cannot defeat charitable exemption where genuine hardship warrants condonation and substantial justice prevail...
Limitation for consequential assessments runs from prescribed authority receipt, while verified purchases cannot be disallowed merely for unanswered s...
Higher depreciation for qualifying commercial vehicles, exempt-income disallowance, research deduction verification, and club-expense treatment clarif...
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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