Personal liberty safeguards restrict arrest after court-directed GST appearance, requiring interim release where authorities overreach pending proceed...
Alternative statutory remedy and delay bar GST writ challenges despite pending rectification, while distinct subject matter permits parallel proceedin...
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...
Reopening of a concluded scrutiny assessment beyond four years requires recorded reasons that independently demonstrate tangible material, a rational link to income escaping assessment, and the taxpayer's failure to make a full and true disclosure of primary facts. Recorded reasons containing factual errors and no connection between an alleged entry operator and the shareholder do not establish due application of mind or a valid reason to believe. Disclosure of shareholder details, banking particulars and confirmations satisfies the taxpayer's obligation; the taxpayer need not draw further factual or legal inferences for the Assessing Officer. The reopening and consequential reassessment were void ab initio and quashed.
Reopening of a concluded scrutiny assessment beyond four years requires recorded reasons that independently demonstrate tangible material, a rational link to income escaping assessment, and the taxpayer's failure to make a full and true disclosure of primary facts. Recorded reasons containing factual errors and no connection between an alleged entry operator and the shareholder do not establish due application of mind or a valid reason to believe. Disclosure of shareholder details, banking particulars and confirmations satisfies the taxpayer's obligation; the taxpayer need not draw further factual or legal inferences for the Assessing Officer. The reopening and consequential reassessment were void ab initio and quashed.
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