Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
Customs-controlled container movement now extends to DP World facilities, subject to segregation, inspections, reconciliation, and EXIM cargo priority...
AO solely relied on unspecified information categorized as 'high risk transactions' of unsecured loans without giving specific details of lenders, amounting to bald allegations. No definitive link or adverse document was present at the time of forming belief. Mere identification of transactions as 'high risk' cannot provide cause for reopening assessment. The reasons recorded give an impression of 'reason to suspect' rather than 'reason to believe' escapement of income as required u/s 147. The purported 'belief' is premised on vague grounds, failing the test of 'reason to believe'. ITAT allowed assessee's appeal.
AO solely relied on unspecified information categorized as 'high risk transactions' of unsecured loans without giving specific details of lenders, amounting to bald allegations. No definitive link or adverse document was present at the time of forming belief. Mere identification of transactions as 'high risk' cannot provide cause for reopening assessment. The reasons recorded give an impression of 'reason to suspect' rather than 'reason to believe' escapement of income as required u/s 147. The purported 'belief' is premised on vague grounds, failing the test of 'reason to believe'. ITAT allowed assessee's appeal.
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