Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
ODR arbitration participation remains mandatory after failed conciliation, while jurisdictional and maintainability objections stay available before t...
Transparency in technical bid evaluation requires disclosed standards and recorded reasons; opaque scoring invalidated tender awards and required fres...
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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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