Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
Release of buyback escrow under the exceptions to Regulation 15B(8) does not bar an independent fraud inquiry under the PFUTP Regulations, because the provision concerns escrow forfeiture or release rather than whether fraud occurred. Internal departmental file notings remain non-binding unless converted into and communicated as a final decision of the competent authority. Fraud must be proved on a balance of probabilities through objective, corroborative circumstances, including trading patterns, contemporaneous records and attributable conduct. The fraud allegation was remanded for fresh adjudication after examination of trading-data discrepancies, inconsistent investigation reports and corroborative material; the appeals were partly allowed.
Release of buyback escrow under the exceptions to Regulation 15B(8) does not bar an independent fraud inquiry under the PFUTP Regulations, because the provision concerns escrow forfeiture or release rather than whether fraud occurred. Internal departmental file notings remain non-binding unless converted into and communicated as a final decision of the competent authority. Fraud must be proved on a balance of probabilities through objective, corroborative circumstances, including trading patterns, contemporaneous records and attributable conduct. The fraud allegation was remanded for fresh adjudication after examination of trading-data discrepancies, inconsistent investigation reports and corroborative material; the appeals were partly allowed.
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