Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
The Tribunal held that a Commissioner (Appeals) may enhance an assessment only in respect of matters or sources of income expressly or by clear implication considered by the Assessing Officer. A separate alleged commission income for facilitating accommodation entries was a new source, because the assessment had only made a protective addition on the entry itself and had not examined any commission income. That new source could not be introduced through appellate enhancement and, if otherwise sustainable, had to be pursued through separate statutory proceedings for escaped or erroneous assessment. The enhancement was deleted and the assessee's appeal was allowed.
The Tribunal held that a Commissioner (Appeals) may enhance an assessment only in respect of matters or sources of income expressly or by clear implication considered by the Assessing Officer. A separate alleged commission income for facilitating accommodation entries was a new source, because the assessment had only made a protective addition on the entry itself and had not examined any commission income. That new source could not be introduced through appellate enhancement and, if otherwise sustainable, had to be pursued through separate statutory proceedings for escaped or erroneous assessment. The enhancement was deleted and the assessee's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
