Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Unproved and non-genuine purchase claims cannot be limited to an estimated profit addition, since that would allow deduction of the remaining unproved expenditure. Full disallowance was restored for the relevant later assessment years, while the unchallenged restriction for earlier years remained undisturbed. Settlement Commission finality extends only to matters and assessment years expressly covered and cannot provide blanket protection for subsequent years. Search-based additions deleted without independent verification required reconsideration, but assessment must follow natural justice: the assessee must receive all relied-upon material and statements and have an adequate opportunity to respond. The remaining additions were remanded for fresh assessment.
Unproved and non-genuine purchase claims cannot be limited to an estimated profit addition, since that would allow deduction of the remaining unproved expenditure. Full disallowance was restored for the relevant later assessment years, while the unchallenged restriction for earlier years remained undisturbed. Settlement Commission finality extends only to matters and assessment years expressly covered and cannot provide blanket protection for subsequent years. Search-based additions deleted without independent verification required reconsideration, but assessment must follow natural justice: the assessee must receive all relied-upon material and statements and have an adequate opportunity to respond. The remaining additions were remanded for fresh assessment.
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