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...
Reopening under section 147 after a search was upheld, as the tribunal found no infirmity in the assumption of jurisdiction and rejected the challenge to validity of reassessment. On the merits, commission income from an accommodation entry operation was to be estimated at 0.15%, not the higher rate proposed by the Assessing Officer, but the quantification basis was vitiated because the tally data and forensic analysis report had not been confronted to the assessee. That breach of natural justice required fresh computation. The matter was remanded to the Assessing Officer to supply the material, consider the assessee's submissions, recompute turnover, and then apply the 0.15% rate; the Revenue's challenge to that rate was dismissed.
Reopening under section 147 after a search was upheld, as the tribunal found no infirmity in the assumption of jurisdiction and rejected the challenge to validity of reassessment. On the merits, commission income from an accommodation entry operation was to be estimated at 0.15%, not the higher rate proposed by the Assessing Officer, but the quantification basis was vitiated because the tally data and forensic analysis report had not been confronted to the assessee. That breach of natural justice required fresh computation. The matter was remanded to the Assessing Officer to supply the material, consider the assessee's submissions, recompute turnover, and then apply the 0.15% rate; the Revenue's challenge to that rate was dismissed.
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