“Section 183(1)”

Reopening assessment beyond four years under Section 147 is permissible only if the assessee failed to disclose fully and truly the material facts necessary for assessment. Mere change of opinion is not a valid ground for reopening.

Penalty proceedings are vitiated if the Assessing Officer's satisfaction is not based on the order passed by the Assessing Officer or the CIT(A). The jurisdiction to impose penalty rests with the authority that is satisfied about the concealment or furnishing of inaccurate particulars of income.

A tolerance range of ten times the assessee's turnover on either side is a proper method for determining comparable companies. Companies with turnovers significantly higher or lower than this range, or those with high brand value, may not be considered comparable.

Remission of a liability in a subsequent assessment year, for which a deduction was obtained in an earlier year, cannot be taxed as income if the assessee maintains accounts on the mercantile system.

An Assessing Officer cannot assume jurisdiction to reassess income based solely on a reconsideration of the same material that was available during the original assessment, as this would amount to a mere change of opinion and not the discovery of fresh tangible material. Reopening an assessment requires fresh tangible material coming into possession after the original assessment was concluded.

Courts and tribunals cannot extend relief against explicit legislative intent, even if hardship results. The plain text of a tax law must be followed.

Courts and tribunals cannot grant relief that contradicts legislative intent, even if it appears harsh, as the law must be applied as written.