Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Addition based on unsubstantiated documents like loose sheets, jottings, and Excel sheets - unaccounted cash receipts from students - cannot be sustained. Statements recorded solely cannot constitute incriminating material for additions. Unsubstantiated loose papers without corroboration by inquiry or leading to undisclosed assets cannot be basis for additions. Suspicion alone cannot replace evidence. AO failed to establish live link between seized material and unaccounted fees resulting in undisclosed assets. Uncorroborated seized material alone cannot be considered conclusive evidence. Presumption u/s 132(4) is rebuttable. AO should act judicially on adequate material, not arbitrarily. Additions cannot be made without examining concerned students/parents. Mere notes in diaries/loose sheets require corroboration. Non-speaking documents without corroborative evidence showing undisclosed income cannot be relied upon for additions.
Addition based on unsubstantiated documents like loose sheets, jottings, and Excel sheets - unaccounted cash receipts from students - cannot be sustained. Statements recorded solely cannot constitute incriminating material for additions. Unsubstantiated loose papers without corroboration by inquiry or leading to undisclosed assets cannot be basis for additions. Suspicion alone cannot replace evidence. AO failed to establish live link between seized material and unaccounted fees resulting in undisclosed assets. Uncorroborated seized material alone cannot be considered conclusive evidence. Presumption u/s 132(4) is rebuttable. AO should act judicially on adequate material, not arbitrarily. Additions cannot be made without examining concerned students/parents. Mere notes in diaries/loose sheets require corroboration. Non-speaking documents without corroborative evidence showing undisclosed income cannot be relied upon for additions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4826 
Join Channel 
