Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Reopening of assessment u/s 147 - non independent application of mind by AO - Scope of borrowed satisfaction - The Appellate Tribunal found that the reopening was solely based on assumptions without concrete evidence linking the assessee to the alleged transactions. It was observed that the Assessing Officer did not adequately apply his mind before issuing the notice, and the conclusions were merely a reproduction of the investigation report. Citing precedents, the Tribunal emphasized the necessity of an independent application of mind by the Assessing Officer and concluded that the notice was invalid.
Reopening of assessment u/s 147 - non independent application of mind by AO - Scope of borrowed satisfaction - The Appellate Tribunal found that the reopening was solely based on assumptions without concrete evidence linking the assessee to the alleged transactions. It was observed that the Assessing Officer did not adequately apply his mind before issuing the notice, and the conclusions were merely a reproduction of the investigation report. Citing precedents, the Tribunal emphasized the necessity of an independent application of mind by the Assessing Officer and concluded that the notice was invalid.
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