Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
AO issued notice u/s 148A(b) alleging petitioner received accommodation entries from entities controlled by Sh. Joginder Pal Gupta. Petitioner denied receiving any amount and provided bank account details. HC held AO cannot reopen assessment without examining material to establish petitioner received entries in bank accounts. Mere allegation of accommodation entries without substantiating material is insufficient. AO must ascertain basic facts are sustainable before reopening assessment. Impugned notices u/s 148, 148A(b) and order u/s 148A(d) set aside by HC.
AO issued notice u/s 148A(b) alleging petitioner received accommodation entries from entities controlled by Sh. Joginder Pal Gupta. Petitioner denied receiving any amount and provided bank account details. HC held AO cannot reopen assessment without examining material to establish petitioner received entries in bank accounts. Mere allegation of accommodation entries without substantiating material is insufficient. AO must ascertain basic facts are sustainable before reopening assessment. Impugned notices u/s 148, 148A(b) and order u/s 148A(d) set aside by HC.
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