Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Reassessment initiated on a mistaken factual premise and without a live nexus to incriminating material was held unsustainable, as the record did not link the assessee to the seized third-party material and the jurisdictional approval objection was unrebutted. The Tribunal also found that approval under the reassessment provisions had not been shown to be validly obtained and that the sanction was mechanical, so the reassessment order was quashed. On the alleged on-money addition, unexplained reliance on un-confronted Excel entries and third-party statements could not displace the assessee's banking records and other documents, and the section 69 addition was deleted.
Reassessment initiated on a mistaken factual premise and without a live nexus to incriminating material was held unsustainable, as the record did not link the assessee to the seized third-party material and the jurisdictional approval objection was unrebutted. The Tribunal also found that approval under the reassessment provisions had not been shown to be validly obtained and that the sanction was mechanical, so the reassessment order was quashed. On the alleged on-money addition, unexplained reliance on un-confronted Excel entries and third-party statements could not displace the assessee's banking records and other documents, and the section 69 addition was deleted.
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