Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
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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