Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Reassessment initiated under an incorrect and non-operative PAN was treated as a jurisdictional defect, not a mere procedural lapse, because the assessee had disclosed the transactions under the correct PAN and the reply under section 148A was not considered before issuing notice; the proceedings were also held time-barred. On merits, cash deposits were accepted as business receipts where the books and explanation were unrebutted, and rejection of accounts solely for want of a tax audit was unjustified. The FDR investments were likewise explained from renewal of earlier deposits and the same business receipts, so the addition could not survive and double taxation of the same funds was impermissible.
Reassessment initiated under an incorrect and non-operative PAN was treated as a jurisdictional defect, not a mere procedural lapse, because the assessee had disclosed the transactions under the correct PAN and the reply under section 148A was not considered before issuing notice; the proceedings were also held time-barred. On merits, cash deposits were accepted as business receipts where the books and explanation were unrebutted, and rejection of accounts solely for want of a tax audit was unjustified. The FDR investments were likewise explained from renewal of earlier deposits and the same business receipts, so the addition could not survive and double taxation of the same funds was impermissible.
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