Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Reassessment under section 148 was quashed because the recorded reasons were vague, factually inconsistent and unsupported by an independent application of mind. The Tribunal found that the Assessing Officer relied on portal information and investigation material alleging fictitious profit, but the reassessment order treated the same figure differently and failed to maintain the very basis on which jurisdiction was assumed. No live nexus was shown between the material and escapement of income, and the assessee's purchase, sale, bank and D-Mat records were not dislodged by adverse material. The reopening was held to rest on borrowed satisfaction, so the reassessment was unsustainable and the merits were not examined.
Reassessment under section 148 was quashed because the recorded reasons were vague, factually inconsistent and unsupported by an independent application of mind. The Tribunal found that the Assessing Officer relied on portal information and investigation material alleging fictitious profit, but the reassessment order treated the same figure differently and failed to maintain the very basis on which jurisdiction was assumed. No live nexus was shown between the material and escapement of income, and the assessee's purchase, sale, bank and D-Mat records were not dislodged by adverse material. The reopening was held to rest on borrowed satisfaction, so the reassessment was unsustainable and the merits were not examined.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
