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...
Non-participating bidders cannot disturb concluded liquidation sales on speculative prejudice, while costs for such challenges must remain proportiona...
Third-party search material triggering reopening is governed, under the pre-amendment framework, by the search-assessment mechanism rather than ordinary reassessment. Material handover to the receiving Assessing Officer is treated as the third-party search date for computing the ten-year assessment block; consequently, the notice for AY 2013-14 was time-barred. Extended reassessment limitation also cannot be invoked by aggregating alleged expenditure from separate furniture and interior-work orders unless it relates to the same event or occasion. Distinct orders, payment dates and time periods constituted separate events, making the extended period unavailable. Reassessment notices for AYs 2013-14 and 2014-15 were therefore quashed as barred by limitation.
Third-party search material triggering reopening is governed, under the pre-amendment framework, by the search-assessment mechanism rather than ordinary reassessment. Material handover to the receiving Assessing Officer is treated as the third-party search date for computing the ten-year assessment block; consequently, the notice for AY 2013-14 was time-barred. Extended reassessment limitation also cannot be invoked by aggregating alleged expenditure from separate furniture and interior-work orders unless it relates to the same event or occasion. Distinct orders, payment dates and time periods constituted separate events, making the extended period unavailable. Reassessment notices for AYs 2013-14 and 2014-15 were therefore quashed as barred by limitation.
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