Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
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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