Aventis Pharma Ltd v.ACIT 2010(Bom.)
Power u/s147 to re-open an assessment is conditional on formation of REASON TO BELIEVE that taxable income has escaped assessment.
Existence of TANGIBLE MATERIAL is ESSENTIAL to safegaurd against arbitrary excercise of this power.
Mere change of opinion is not sufficient.
Power u/s147 to re-open an assessment is conditional on formation of REASON TO BELIEVE that taxable income has escaped assessment.
Existence of TANGIBLE MATERIAL is ESSENTIAL to safegaurd against arbitrary excercise of this power.
Mere change of opinion is not sufficient.
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