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Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The HC set aside the respondent's order dated 03.09.2024 and allowed the petition. The court held that the Assessing Officer's unilateral debit from the petitioner's cash ledger toward disputed interest amounts was erroneous, without jurisdiction, and contrary to Section 107(7) mandate. The court determined that where an appellant has paid amounts under sub-section (6), recovery proceedings for balance amounts are deemed stayed per Section 107(7). Consequently, the unilateral debit undertaken by the Assessing Officer was impermissible, rendering the rejection order unsustainable and liable to be set aside.
The HC set aside the respondent's order dated 03.09.2024 and allowed the petition. The court held that the Assessing Officer's unilateral debit from the petitioner's cash ledger toward disputed interest amounts was erroneous, without jurisdiction, and contrary to Section 107(7) mandate. The court determined that where an appellant has paid amounts under sub-section (6), recovery proceedings for balance amounts are deemed stayed per Section 107(7). Consequently, the unilateral debit undertaken by the Assessing Officer was impermissible, rendering the rejection order unsustainable and liable to be set aside.
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