Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
Reassessment under sections 148A(b) and 148A(d) requires the reasons recorded for reopening to correspond with the information and grounds put to the assessee for explanation. Where a notice treated land as undisclosed and an unexplained investment, but the subsequent satisfaction accepted its disclosure and instead questioned the source of acquisition funds, the basis of reopening changed completely. Fresh or supplementary reasons cannot sustain reassessment without prior notice under section 148A(b). The Tribunal therefore quashed the reassessment, leaving the merits of the addition unadjudicated.
Reassessment under sections 148A(b) and 148A(d) requires the reasons recorded for reopening to correspond with the information and grounds put to the assessee for explanation. Where a notice treated land as undisclosed and an unexplained investment, but the subsequent satisfaction accepted its disclosure and instead questioned the source of acquisition funds, the basis of reopening changed completely. Fresh or supplementary reasons cannot sustain reassessment without prior notice under section 148A(b). The Tribunal therefore quashed the reassessment, leaving the merits of the addition unadjudicated.
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TaxTMI 
TaxTMI 
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