Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
Reassessment proceedings require the Assessing Officer to furnish recorded reasons on the taxpayer's request and dispose of objections before continuing the reassessment; non-compliance renders the reassessment unsustainable. For alleged bogus long-term capital gains, contemporaneous banking and demat records, contract notes, securities transaction tax evidence, and proof of share acquisition and sale can establish transaction genuineness. General investigation material or suspicion, without cogent evidence linking the taxpayer to accommodation entries or cash payments to an entry provider, cannot displace that evidence. Additions for unexplained share-sale proceeds and consequential alleged commission were deleted.
Reassessment proceedings require the Assessing Officer to furnish recorded reasons on the taxpayer's request and dispose of objections before continuing the reassessment; non-compliance renders the reassessment unsustainable. For alleged bogus long-term capital gains, contemporaneous banking and demat records, contract notes, securities transaction tax evidence, and proof of share acquisition and sale can establish transaction genuineness. General investigation material or suspicion, without cogent evidence linking the taxpayer to accommodation entries or cash payments to an entry provider, cannot displace that evidence. Additions for unexplained share-sale proceeds and consequential alleged commission were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
