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...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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ITAT upheld invalid reassessment where the show-cause notice under the reopening procedure was not accompanied by the relied-upon material, despite the assessee's request, and held that RMS or Insight inputs did not dispense with independent verification, disclosure of material, or observance of natural justice. It further held that the appellate authority could test the legality of the reopening while hearing the reassessment appeal. Additions based on third-party seized papers, statements and loose sheets failed because the material was not properly furnished, cross-examination was denied, and the documents were uncorroborated. Section 69A was held inapplicable to alleged cash borrowing. Later-year notices were also held time-barred, so the consequential reassessments did not survive.
ITAT upheld invalid reassessment where the show-cause notice under the reopening procedure was not accompanied by the relied-upon material, despite the assessee's request, and held that RMS or Insight inputs did not dispense with independent verification, disclosure of material, or observance of natural justice. It further held that the appellate authority could test the legality of the reopening while hearing the reassessment appeal. Additions based on third-party seized papers, statements and loose sheets failed because the material was not properly furnished, cross-examination was denied, and the documents were uncorroborated. Section 69A was held inapplicable to alleged cash borrowing. Later-year notices were also held time-barred, so the consequential reassessments did not survive.
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