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...
Reassessment for unexplained investment in immovable property may be initiated where the income-tax return was only processed and material indicates that the investment, including an unexplained cash component, was disproportionate to disclosed income. Disclosure of the property purchase in a wealth-tax return does not by itself establish disclosure in the income-tax return of material facts concerning the source of funds or the transaction's true nature. Explanation 2(b) to section 147 may therefore apply. The assessing officer is not deemed to have considered information contained only in the wealth-tax return. Sanction under section 151 is satisfied where the approving authority records satisfaction on the assessing officer's recorded reasons.
Reassessment for unexplained investment in immovable property may be initiated where the income-tax return was only processed and material indicates that the investment, including an unexplained cash component, was disproportionate to disclosed income. Disclosure of the property purchase in a wealth-tax return does not by itself establish disclosure in the income-tax return of material facts concerning the source of funds or the transaction's true nature. Explanation 2(b) to section 147 may therefore apply. The assessing officer is not deemed to have considered information contained only in the wealth-tax return. Sanction under section 151 is satisfied where the approving authority records satisfaction on the assessing officer's recorded reasons.
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