Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
Concurrent factual findings on cash credits recorded in an impounded diary did not give rise to a substantial question of law in the income-tax appeals. The credits recorded in a partner's name were treated as unaccounted funds introduced by the partner into the partnership firm after considering the stated unaccounted sources. A plea to assess the entire diary amount in the partner's hands required reconsideration of those factual findings rather than resolution of a legal issue. The challenges therefore failed for want of a substantial question of law.
Concurrent factual findings on cash credits recorded in an impounded diary did not give rise to a substantial question of law in the income-tax appeals. The credits recorded in a partner's name were treated as unaccounted funds introduced by the partner into the partnership firm after considering the stated unaccounted sources. A plea to assess the entire diary amount in the partner's hands required reconsideration of those factual findings rather than resolution of a legal issue. The challenges therefore failed for want of a substantial question of law.
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