Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Reassessment cannot be sustained for an unrelated income item where the income forming the recorded reasons is accepted and no addition is made on that basis. The notes explain that an Assessing Officer who initiated reassessment to examine share application money could not independently add an unsecured loan identified through separate information without issuing a fresh notice under section 148. Applying the principle in Jet Airways and a subsequent ITAT decision, the reassessment addition was treated as outside the permissible scope of reassessment. The assessee succeeded on this legal issue, and the merits of the unsecured-loan addition and other grounds were not examined.
Reassessment cannot be sustained for an unrelated income item where the income forming the recorded reasons is accepted and no addition is made on that basis. The notes explain that an Assessing Officer who initiated reassessment to examine share application money could not independently add an unsecured loan identified through separate information without issuing a fresh notice under section 148. Applying the principle in Jet Airways and a subsequent ITAT decision, the reassessment addition was treated as outside the permissible scope of reassessment. The assessee succeeded on this legal issue, and the merits of the unsecured-loan addition and other grounds were not examined.
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