Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
HC, in a writ petition challenging a SCN seeking finalization of provisional assessments for Bills of Entry dated August 2010 to September 2013, found substantial merit in the importer-petitioner's contentions. Relying on the principle that provisional assessments must be finalized within a reasonable time, approximately five years, the HC held that a delay of 12-15 years is prima facie unreasonable. The Court also accepted that evidence of end-use after 15 years would be impracticable. Holding that a strong prima facie case exists, HC granted ad-interim relief and listed the matter for 8 January 2026.
HC, in a writ petition challenging a SCN seeking finalization of provisional assessments for Bills of Entry dated August 2010 to September 2013, found substantial merit in the importer-petitioner's contentions. Relying on the principle that provisional assessments must be finalized within a reasonable time, approximately five years, the HC held that a delay of 12-15 years is prima facie unreasonable. The Court also accepted that evidence of end-use after 15 years would be impracticable. Holding that a strong prima facie case exists, HC granted ad-interim relief and listed the matter for 8 January 2026.
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