Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Under the post-1.4.2021 reassessment scheme, notice under section 148 can be issued where the Assessing Officer has material indicating escapement of income, and the sufficiency of incriminating material is tested in reassessment, not at the notice stage; the reopening was therefore upheld. The Tribunal also held that section 170 governs successor liability on amalgamation and that absence of pending proceedings on the amalgamation date did not invalidate action against the successor. On merits, additions treating sale proceeds of earlier-year investments as unexplained cash credit, and related commission for alleged accommodation entries, were deleted because the transactions were supported by banking records, the investments had earlier been accepted, and reliance on third-party statements without cross-examination violated natural justice.
Under the post-1.4.2021 reassessment scheme, notice under section 148 can be issued where the Assessing Officer has material indicating escapement of income, and the sufficiency of incriminating material is tested in reassessment, not at the notice stage; the reopening was therefore upheld. The Tribunal also held that section 170 governs successor liability on amalgamation and that absence of pending proceedings on the amalgamation date did not invalidate action against the successor. On merits, additions treating sale proceeds of earlier-year investments as unexplained cash credit, and related commission for alleged accommodation entries, were deleted because the transactions were supported by banking records, the investments had earlier been accepted, and reliance on third-party statements without cross-examination violated natural justice.
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