Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Reassessment was upheld because prior approval for the section 143(2) notice was found to have been communicated before issue, and the section 151 sanction and section 148B approval were not shown to suffer from non-application of mind. The Tribunal also held that seized books and digital cash ledgers found at third-party premises could be used where evidence showed group possession, control and participation in maintaining the records. On quantum, it rejected separate taxation of alleged on-money, V A/c and other entries on gross or estimated basis, holding that the seized material represented a single common cash pool and income had to be recomputed only on a unified year-wise peak credit basis in the assessee's hands.
Reassessment was upheld because prior approval for the section 143(2) notice was found to have been communicated before issue, and the section 151 sanction and section 148B approval were not shown to suffer from non-application of mind. The Tribunal also held that seized books and digital cash ledgers found at third-party premises could be used where evidence showed group possession, control and participation in maintaining the records. On quantum, it rejected separate taxation of alleged on-money, V A/c and other entries on gross or estimated basis, holding that the seized material represented a single common cash pool and income had to be recomputed only on a unified year-wise peak credit basis in the assessee's hands.
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