Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
Competent sanction under section 151 is a substantive jurisdictional safeguard for reassessment. TOLA extended the authority under section 151(i) only until 30 June 2021; for notices issued in July 2022, approval from the higher authority under section 151(ii) was required. Approval by the Principal Commissioner was neither substantial compliance nor curable under section 292B, so the reassessment and consequential addition were annulled. Penalty for failure to obtain a tax audit requires proof of business activity and legally relevant turnover exceeding the prescribed threshold. Purchases, delivery-based sales and unproved derivative transactions could not establish turnover; consistent investment treatment and capital-gains disclosure also demonstrated reasonable cause. The audit penalty was deleted.
Competent sanction under section 151 is a substantive jurisdictional safeguard for reassessment. TOLA extended the authority under section 151(i) only until 30 June 2021; for notices issued in July 2022, approval from the higher authority under section 151(ii) was required. Approval by the Principal Commissioner was neither substantial compliance nor curable under section 292B, so the reassessment and consequential addition were annulled. Penalty for failure to obtain a tax audit requires proof of business activity and legally relevant turnover exceeding the prescribed threshold. Purchases, delivery-based sales and unproved derivative transactions could not establish turnover; consistent investment treatment and capital-gains disclosure also demonstrated reasonable cause. The audit penalty was deleted.
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