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...
Natural justice was prima facie breached where an unexplained-expenditure addition based on import data was made without meaningful invoice-wise or bill-of-entry-wise particulars. Recorded imports supplied by the assessee exceeded the aggregate data relied on, and apparent duplication in departmental data prevented reconciliation. The High Court treated the addition as raising strong triable issues and stayed recovery pending first appeal, while requiring the appellate authority to decide independently on merits. Administrative directions concerning deposit of a prescribed demand percentage did not fetter the Court's stay power; Revenue's insistence on a 20% payment was rejected. The assessment observations remained confined to the prima facie stay determination.
Natural justice was prima facie breached where an unexplained-expenditure addition based on import data was made without meaningful invoice-wise or bill-of-entry-wise particulars. Recorded imports supplied by the assessee exceeded the aggregate data relied on, and apparent duplication in departmental data prevented reconciliation. The High Court treated the addition as raising strong triable issues and stayed recovery pending first appeal, while requiring the appellate authority to decide independently on merits. Administrative directions concerning deposit of a prescribed demand percentage did not fetter the Court's stay power; Revenue's insistence on a 20% payment was rejected. The assessment observations remained confined to the prima facie stay determination.
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TaxTMI 
TaxTMI 
of 4881 
