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Risk-based selective vessel boarding requires accurate declarations and preserves master and agent liability where physical inspections are not select...
Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Section 153(5) applies where effect can be given without making a fresh assessment or reassessment. Where a Tribunal remand requires the Assessing Officer to undertake fresh consideration, the limitation period for fresh assessment under section 153(3) applies; the proviso to section 153(5) also covers matters requiring verification or an opportunity of hearing. Foreign currency may be treated as unexplained money where the taxpayer provides inconsistent explanations and fails to prove its source through satisfactory evidence, including acquisition from authorised dealers. FEMA confiscation for excess possession does not by itself establish the currency's source for income-tax purposes. The addition as deemed income and the associated tax treatment were sustained.
Section 153(5) applies where effect can be given without making a fresh assessment or reassessment. Where a Tribunal remand requires the Assessing Officer to undertake fresh consideration, the limitation period for fresh assessment under section 153(3) applies; the proviso to section 153(5) also covers matters requiring verification or an opportunity of hearing. Foreign currency may be treated as unexplained money where the taxpayer provides inconsistent explanations and fails to prove its source through satisfactory evidence, including acquisition from authorised dealers. FEMA confiscation for excess possession does not by itself establish the currency's source for income-tax purposes. The addition as deemed income and the associated tax treatment were sustained.
Note: It is a system-generated summary and is for quick reference only.