https://www.taxtmi.com/caselaws?id=300901 Reopening was invalid because the recorded reasons were incomplete, no fresh tangible material supported the change of opinion, and the statutory approval for reopening was mechanically obtained without proper compliance with the reopening safeguards. The reassessment was therefore void in law. In addition, a life insurance company's income had to be computed under the special insurance tax regime and actuarial method prescribed by the First Schedule, so ordinary accounting adjustments could not be used to tax internal transfers as losses. The addition for negative reserves was also unsustainable because it was only a disclosure item with no independent taxability under that scheme. The assessee succeeded on both the jurisdictional challenge and the substantive additions. en-us Wed, 31 Mar 2021 00:00:00 +0530 Thu, 03 Mar 2022 06:47:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=300901 Reopening was invalid because the recorded reasons were incomplete, no fresh tangible material supported the change of opinion, and the statutory approval for reopening was mechanically obtained without proper compliance with the reopening safeguards. The reassessment was therefore void in law. In addition, a life insurance company's income had to be computed under the special insurance tax regime and actuarial method prescribed by the First Schedule, so ordinary accounting adjustments could not be used to tax internal transfers as losses. The addition for negative reserves was also unsustainable because it was only a disclosure item with no independent taxability under that scheme. The assessee succeeded on both the jurisdictional challenge and the substantive additions. Case-Laws Income Tax Wed, 31 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=300901