Settlement application eligibility requires a pending assessment when filed, preventing an extra prior-eligibility condition from blocking considerati...
Reassessment for unreturned property sales survives where transfer information, non-filing, and unsupported exemption claims establish a prima facie l...
Profit-element taxation limits additions for unaccounted flat-sale receipts and grey-market purchases, while reliable search records support partial a...
Clean-slate sale of a corporate debtor as a going concern extinguishes pre-existing liabilities and investigations, preventing reassessment from being based on an alleged earlier interest liability. Reopening cannot rest on conjecture that unpaid interest was deducted or that a liability ceased where available accounts could verify the claim and the section 148A order itself records no cessation. An order under section 148A must remain within the show-cause notice; adding an unrelated bogus-purchase allegation without notice or hearing breaches natural justice and indicates non-application of mind. On these grounds, the reassessment notice and section 148A order were quashed.
Clean-slate sale of a corporate debtor as a going concern extinguishes pre-existing liabilities and investigations, preventing reassessment from being based on an alleged earlier interest liability. Reopening cannot rest on conjecture that unpaid interest was deducted or that a liability ceased where available accounts could verify the claim and the section 148A order itself records no cessation. An order under section 148A must remain within the show-cause notice; adding an unrelated bogus-purchase allegation without notice or hearing breaches natural justice and indicates non-application of mind. On these grounds, the reassessment notice and section 148A order were quashed.
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