Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof...
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Reopening based on a broker's seized inquiry register failed where the entry did not show a live and direct nexus with the assessee's transaction. The entry was older than the purchase, referred to a larger land area, named another person, and was unsupported by any inquiry linking the assessee to undisclosed consideration. The searched person's statement also indicated that such registers recorded land available for sale, not necessarily actual on-money dealings. On these facts, the material could not justify reopening a later assessment year, and the notice under Section 148 was quashed as unsustainable.
Reopening based on a broker's seized inquiry register failed where the entry did not show a live and direct nexus with the assessee's transaction. The entry was older than the purchase, referred to a larger land area, named another person, and was unsupported by any inquiry linking the assessee to undisclosed consideration. The searched person's statement also indicated that such registers recorded land available for sale, not necessarily actual on-money dealings. On these facts, the material could not justify reopening a later assessment year, and the notice under Section 148 was quashed as unsustainable.
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