Pre-trial bail granted where custodial period, documentary prosecution, and magistrate-triable offence favor release subject to surety and no witness ...
Allowability of Salary Exemptions: Form 16 entries can substantiate HRA and other salary exemptions, and home loan interest is deductible for a self-o...
Capital gains exemption: payment for plot, architect fees and bona fide commencement of construction can satisfy utilisation requirement and secure re...
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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