Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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ITAT held that additions for alleged capital gains and unexplained cash under section 69A, founded solely on uncorroborated personal diary entries and retracted statements of employees/directors, lacked evidentiary foundation and were deleted. Reassessment proceedings initiated by the jurisdictional AO were declared void ab initio as jurisdiction had vested in the Faceless Assessing Officer under the notified scheme; consequently the section 148 notice was coram non judice. The assessment order was also vitiated for failure to generate/quote a valid pre-generated DIN, rendering it a nullity. The appellate enhancement sought by Revenue was held not maintainable for want of cogent material within the scope of matters before the AO/CIT(A).
ITAT held that additions for alleged capital gains and unexplained cash under section 69A, founded solely on uncorroborated personal diary entries and retracted statements of employees/directors, lacked evidentiary foundation and were deleted. Reassessment proceedings initiated by the jurisdictional AO were declared void ab initio as jurisdiction had vested in the Faceless Assessing Officer under the notified scheme; consequently the section 148 notice was coram non judice. The assessment order was also vitiated for failure to generate/quote a valid pre-generated DIN, rendering it a nullity. The appellate enhancement sought by Revenue was held not maintainable for want of cogent material within the scope of matters before the AO/CIT(A).
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