Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
HC held that the AO's reassessment notice under Section 147 was invalid. The AO mechanically recorded reasons based on third-party information without providing substantive evidence directly linking the petitioner to any undisclosed income. The court found no material connection between the survey operation and the petitioner's transactions. The AO's refusal to disclose confidential information to the assessee violated procedural fairness, rendering the reopening of assessment arbitrary and illegal. Consequently, the court quashed the reassessment notice, deciding in favor of the assessee and emphasizing the need for concrete, specific reasons when initiating reassessment proceedings.
HC held that the AO's reassessment notice under Section 147 was invalid. The AO mechanically recorded reasons based on third-party information without providing substantive evidence directly linking the petitioner to any undisclosed income. The court found no material connection between the survey operation and the petitioner's transactions. The AO's refusal to disclose confidential information to the assessee violated procedural fairness, rendering the reopening of assessment arbitrary and illegal. Consequently, the court quashed the reassessment notice, deciding in favor of the assessee and emphasizing the need for concrete, specific reasons when initiating reassessment proceedings.
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