Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
ITAT quashed reassessment initiated u/s 147 as the AO lacked valid reasons to form belief that income of the assessee had escaped assessment. The tribunal found evidentiary support for sales to an unnamed counterparty, receipt of sale proceeds through banking channels, and no rebuttal by the AO to impugn genuineness; mere non-filing of returns by the counterparty did not suffice to treat receipts as unexplained cash credit u/s 68 or to constitute a reason to form belief under s.147. Reopening was also held to amount to impermissible change of opinion since identical sales were examined and accepted in the original s.143(3) assessment; reassessment was therefore invalid.
ITAT quashed reassessment initiated u/s 147 as the AO lacked valid reasons to form belief that income of the assessee had escaped assessment. The tribunal found evidentiary support for sales to an unnamed counterparty, receipt of sale proceeds through banking channels, and no rebuttal by the AO to impugn genuineness; mere non-filing of returns by the counterparty did not suffice to treat receipts as unexplained cash credit u/s 68 or to constitute a reason to form belief under s.147. Reopening was also held to amount to impermissible change of opinion since identical sales were examined and accepted in the original s.143(3) assessment; reassessment was therefore invalid.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
