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...
Prima facie substance in a limitation challenge to reassessment, coupled with a high-pitched assessment, warranted unconditional protection from recovery pending appeal. The stay-rejection order failed to address the taxpayer's material contentions solely because an appeal was pending. Financial capacity could not be inferred from gross turnover without considering returned income. The rejection was set aside, recovery of the reassessment demand was stayed until appeal disposal, and the appellate authority was to determine the appeal independently and expeditiously on its merits.
Prima facie substance in a limitation challenge to reassessment, coupled with a high-pitched assessment, warranted unconditional protection from recovery pending appeal. The stay-rejection order failed to address the taxpayer's material contentions solely because an appeal was pending. Financial capacity could not be inferred from gross turnover without considering returned income. The rejection was set aside, recovery of the reassessment demand was stayed until appeal disposal, and the appellate authority was to determine the appeal independently and expeditiously on its merits.
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