Unsigned third-party records cannot establish on-money payments without corroboration and cross-examination, requiring deletion of the related additio...
Service-tax exemptions for railway and Government works restrict de novo reassessment, while unsupported limitation and consultation failures invalida...
Reassessment founded on misstated facts, mechanically adopted investigation inputs, and transactions already examined in scrutiny constitutes an impermissible change of opinion and is invalid. Section 69A does not apply to recorded equity-share purchases where contract notes, broker records, and bank evidence establish the source of investment. It also cannot treat accounted sale proceeds of recorded shares as unexplained investment; taxing those proceeds again after the related income has been offered results in double taxation. Failure to verify supporting material or permit cross-examination of a retracted third-party statement further undermines the addition.
Reassessment founded on misstated facts, mechanically adopted investigation inputs, and transactions already examined in scrutiny constitutes an impermissible change of opinion and is invalid. Section 69A does not apply to recorded equity-share purchases where contract notes, broker records, and bank evidence establish the source of investment. It also cannot treat accounted sale proceeds of recorded shares as unexplained investment; taxing those proceeds again after the related income has been offered results in double taxation. Failure to verify supporting material or permit cross-examination of a retracted third-party statement further undermines the addition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4935 
