Limitation in customs appeals permits exclusion for bona fide refund proceedings, enabling restoration of Bill of Entry assessment challenges on merit...
Warehousing permission requires deposit at the designated bonded warehouse; unauthorised diversion triggers confiscation, redemption fine and importer...
Reassessment based on Investigation Wing information may rest on tangible material where it specifically links alleged accommodation entries to the taxpayer's loan transaction, creating a live nexus and demonstrating independent application of mind rather than borrowed satisfaction. For an unsecured-loan credit, confirmation, PAN, tax return, audited financial statements, bank records, interest payments with tax deduction, and repayment can discharge the taxpayer's burden. Third-party investigation material alone does not displace this evidence without proof that the taxpayer paid cash for the loan or that the lender's funds belonged to the taxpayer. The reassessment was sustained, while the cash-credit addition was deleted.
Reassessment based on Investigation Wing information may rest on tangible material where it specifically links alleged accommodation entries to the taxpayer's loan transaction, creating a live nexus and demonstrating independent application of mind rather than borrowed satisfaction. For an unsecured-loan credit, confirmation, PAN, tax return, audited financial statements, bank records, interest payments with tax deduction, and repayment can discharge the taxpayer's burden. Third-party investigation material alone does not displace this evidence without proof that the taxpayer paid cash for the loan or that the lender's funds belonged to the taxpayer. The reassessment was sustained, while the cash-credit addition was deleted.
Note: It is a system-generated summary and is for quick reference only.
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