Reassessing the Thresholds of Section 147: Tangible Material, “Change of Opinion,” and the True Character of Revenue-Sharing in Joint Ventures
In a definitive ruling that tightens the procedural and substantive boundaries of Indian tax law, the Supreme Court of India in Sanand Properties P. Ltd. v. Jt. Commr. of I.T. has recalibrated the jurisdictional triggers for reopening scrutiny assessments under Section 147 of the Income...