Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
ITAT held that the assessments framed u/s 153C read with 153D are invalid for lack of jurisdiction: the deemed date of search was 17.10.2022 so s.153C could not be invoked, the requisite satisfaction note was neither supplied nor properly recorded (a consolidated note for multiple years vitiated proceedings), and sanction u/s 153D was mechanical and without application of mind. Consequential additions were set aside: alleged capital gains based solely on seizure spreadsheets without corroboration were not sustained, the s.54B relief already allowed in earlier s.143(3) proceedings was not revisit-able under s.153C, and reopening under s.148 amounted to change of opinion and was therefore invalid. Appeals allowed in favour of the assessee.
ITAT held that the assessments framed u/s 153C read with 153D are invalid for lack of jurisdiction: the deemed date of search was 17.10.2022 so s.153C could not be invoked, the requisite satisfaction note was neither supplied nor properly recorded (a consolidated note for multiple years vitiated proceedings), and sanction u/s 153D was mechanical and without application of mind. Consequential additions were set aside: alleged capital gains based solely on seizure spreadsheets without corroboration were not sustained, the s.54B relief already allowed in earlier s.143(3) proceedings was not revisit-able under s.153C, and reopening under s.148 amounted to change of opinion and was therefore invalid. Appeals allowed in favour of the assessee.
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TaxTMI 
TaxTMI 
of 4893 
