Condonation of delay permits statutory appeal restoration where inadequate service explanation prevented consideration of reassessment and taxable-inc...
Limitation in customs appeals permits exclusion for bona fide refund proceedings, enabling restoration of Bill of Entry assessment challenges on merit...
Warehousing permission requires deposit at the designated bonded warehouse; unauthorised diversion triggers confiscation, redemption fine and importer...
Reassessment based only on Investigation Wing material was held invalid where the recorded reasons showed no independent inquiry, no tangible material and no live nexus between the information and alleged escapement; in cases reopened beyond four years after scrutiny assessment, the absence of any identified failure to disclose fully and truly also barred jurisdiction. On merits, additions treating share sale proceeds as unexplained credits were deleted because the assessees had already disclosed the corresponding capital gains or losses and supported the transactions with contract notes, bank and demat records, broker ledgers and tax evidence, making a further addition impermissible double addition. General investigation or SEBI material without assessee-specific linkage could not sustain a penny stock allegation. Consequential commission additions were also deleted.
Reassessment based only on Investigation Wing material was held invalid where the recorded reasons showed no independent inquiry, no tangible material and no live nexus between the information and alleged escapement; in cases reopened beyond four years after scrutiny assessment, the absence of any identified failure to disclose fully and truly also barred jurisdiction. On merits, additions treating share sale proceeds as unexplained credits were deleted because the assessees had already disclosed the corresponding capital gains or losses and supported the transactions with contract notes, bank and demat records, broker ledgers and tax evidence, making a further addition impermissible double addition. General investigation or SEBI material without assessee-specific linkage could not sustain a penny stock allegation. Consequential commission additions were also deleted.
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