Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Appointment of Registrars as adjudicating officers under Companies Act reallocates territorial jurisdiction and sets appeal route to Regional Director...
Reassessment beyond three years required the recorded reasons to show that the alleged escaped income was represented by an asset, expenditure, or entry in the books; absent that jurisdictional nexus, the notices and reassessment orders for AYs 2017-18 to 2019-20 were quashed. Material brought by a third person in response to summons during search could not be treated as search-seizure material to sustain notices under the search deeming fiction, so those notices were also invalid. The Tribunal further held that search information must relate to the relevant AY, and the absence of that link vitiated the notices for AYs 2020-21 to 2022-23. On merits, the wholesale two-zeroes theory on all cash entries was rejected, but 16% profit on recomputed unaccounted receipts was sustained.
Reassessment beyond three years required the recorded reasons to show that the alleged escaped income was represented by an asset, expenditure, or entry in the books; absent that jurisdictional nexus, the notices and reassessment orders for AYs 2017-18 to 2019-20 were quashed. Material brought by a third person in response to summons during search could not be treated as search-seizure material to sustain notices under the search deeming fiction, so those notices were also invalid. The Tribunal further held that search information must relate to the relevant AY, and the absence of that link vitiated the notices for AYs 2020-21 to 2022-23. On merits, the wholesale two-zeroes theory on all cash entries was rejected, but 16% profit on recomputed unaccounted receipts was sustained.
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