Strict construction of customs exemptions denied concession for brake components, while limitation restricted differential duty to timely Bills of Ent...
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The sales declared by the assessee were treated as bogus, leading to an addition u/s 69A. However, the CIT(A) found that the AO accepted the purchases, inventory, and net profit declared by the assessee. The AO's presumption that the assessee rerouted their own funds was not backed by material evidence. Consequently, the addition was dismissed. Regarding reassessment proceedings, the approval granted u/s 151 was invalid as it was granted for another person's assessment, with the reason merely recorded as 'yes', indicating a mechanical approval. Therefore, the initiation of proceedings itself was held as bad in law, and the assessment made in the assessee's case was set aside. The assessee's appeal was allowed.
The sales declared by the assessee were treated as bogus, leading to an addition u/s 69A. However, the CIT(A) found that the AO accepted the purchases, inventory, and net profit declared by the assessee. The AO's presumption that the assessee rerouted their own funds was not backed by material evidence. Consequently, the addition was dismissed. Regarding reassessment proceedings, the approval granted u/s 151 was invalid as it was granted for another person's assessment, with the reason merely recorded as 'yes', indicating a mechanical approval. Therefore, the initiation of proceedings itself was held as bad in law, and the assessment made in the assessee's case was set aside. The assessee's appeal was allowed.
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TaxTMI 
TaxTMI 
of 4897 
