Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
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...
The crux of the matter revolves around the reopening of assessment u/s 147 of the Act and the addition made u/s 68 treating the share application received as a non-genuine transaction and accommodation entry. The key points are: The reopening was initiated based on the incriminating material found during a search operation at the premises of a third party, indicating that the assessee had obtained an entry from an entry operator. The Assessing Officer heavily relied on the report of the Investigation Wing without independently verifying the facts. The assessee contended that the reopening u/s 147 was unjustified as the incriminating material was recovered during a search, and the proper course should have been proceedings u/s 153C. The ITAT held that the Assessing Officer was not justified in reopening the assessment u/s 147 when the incriminating material was found during a search at a third party's premises. The CIT(A) failed to address the specific grounds raised by the assessee regarding the legality of reopening the assessment.
The crux of the matter revolves around the reopening of assessment u/s 147 of the Act and the addition made u/s 68 treating the share application received as a non-genuine transaction and accommodation entry. The key points are: The reopening was initiated based on the incriminating material found during a search operation at the premises of a third party, indicating that the assessee had obtained an entry from an entry operator. The Assessing Officer heavily relied on the report of the Investigation Wing without independently verifying the facts. The assessee contended that the reopening u/s 147 was unjustified as the incriminating material was recovered during a search, and the proper course should have been proceedings u/s 153C. The ITAT held that the Assessing Officer was not justified in reopening the assessment u/s 147 when the incriminating material was found during a search at a third party's premises. The CIT(A) failed to address the specific grounds raised by the assessee regarding the legality of reopening the assessment.
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