https://www.taxtmi.com/caselaws?id=439650 HC held that reopening assessment under sections 147/148 was invalid. Explanation 1 did not apply because CSR expenditure was mandated by the Companies Act and its proposed disallowance did not constitute an offense; there was no tangible material showing escaped income. Relying on SC precedents, the court rejected retrospective application that would alter the prior law or create a failure to disclose. The assessing officer exceeded jurisdiction in reopening, and the taxpayer's challenge succeeded. en-us Tue, 27 Jun 2023 00:00:00 +0530 Tue, 18 Nov 2025 11:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439650 HC held that reopening assessment under sections 147/148 was invalid. Explanation 1 did not apply because CSR expenditure was mandated by the Companies Act and its proposed disallowance did not constitute an offense; there was no tangible material showing escaped income. Relying on SC precedents, the court rejected retrospective application that would alter the prior law or create a failure to disclose. The assessing officer exceeded jurisdiction in reopening, and the taxpayer's challenge succeeded. Case-Laws Income Tax Tue, 27 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439650