Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
Book-entry conversion of compulsorily convertible debentures into compulsorily convertible preference shares did not constitute a sum received during the relevant previous year for the cash-credit provision. Share premium arising solely from that conversion therefore could not be treated as an unexplained cash credit, rendering the related addition unsustainable. Penalty founded solely on the deleted share-premium addition had no surviving basis. Penalty for non-reporting income also did not arise for principal additions that were set aside; for additions remanded for fresh consideration, penalty could be considered only if they were reiterated. The Revenue's appeals were dismissed for want of a substantial question of law.
Book-entry conversion of compulsorily convertible debentures into compulsorily convertible preference shares did not constitute a sum received during the relevant previous year for the cash-credit provision. Share premium arising solely from that conversion therefore could not be treated as an unexplained cash credit, rendering the related addition unsustainable. Penalty founded solely on the deleted share-premium addition had no surviving basis. Penalty for non-reporting income also did not arise for principal additions that were set aside; for additions remanded for fresh consideration, penalty could be considered only if they were reiterated. The Revenue's appeals were dismissed for want of a substantial question of law.
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TaxTMI 
TaxTMI 
of 4881 
