Capital Asset Conversion Requires Proven Business Stock Treatment; Paper Consideration in Spousal Flat Transfers Does Not Create Taxable Business Inco...
Human-probability test defeats political donation deduction where banking records mask accommodation-entry fund layering and evidence shows non-genuin...
Commercial property status protects capital-gains exemption when residential-house ownership limits are tested, while agricultural-land character gove...
Investigation deposits refunded after failed customs demands fall outside the statutory appellate pre-deposit interest regime and may attract compensa...
Resolution plan finality extinguishes unquantified operational-creditor claims and pending proceedings unless the approved plan expressly preserves th...
Reassessment notices alleging fictitious or accommodation transactions must disclose material particulars and incriminating material that prima facie link the assessee to the alleged transactions. Screenshots of Case Related Information Detail, without the underlying dissemination reports or transaction details, do not provide a meaningful statutory opportunity to respond. The Assessing Officer must independently consider the dissemination material and address objections and supporting evidence. Supplying foundational material only during writ proceedings cannot cure the defect. Failure to meet these requirements resulted in quashing of the reassessment notice, the consequential order, and the subsequent notice, without remand.
Reassessment notices alleging fictitious or accommodation transactions must disclose material particulars and incriminating material that prima facie link the assessee to the alleged transactions. Screenshots of Case Related Information Detail, without the underlying dissemination reports or transaction details, do not provide a meaningful statutory opportunity to respond. The Assessing Officer must independently consider the dissemination material and address objections and supporting evidence. Supplying foundational material only during writ proceedings cannot cure the defect. Failure to meet these requirements resulted in quashing of the reassessment notice, the consequential order, and the subsequent notice, without remand.
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