Unlawful outward remittances via Hawala using proforma invoices and electronic records proved; documents admitted, directors penalised, penalties redu...
Attachment of equivalent-value properties as proceeds of crime upheld; preventive attachment order and confirmation sustained; no independent ED reinv...
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ITAT allowed the assessee's appeal and quashed the reassessment order passed u/s 147 r.w.s. 144B. The AO had reopened the assessment solely on the belief that income had escaped assessment by non-application of s.50C (capital gains on transfer of land/building). However, in the reassessment, no addition was made under s.50C; instead, the AO invoked s.43CA (business income on transfer of land/building held as stock-in-trade), which was never part of the recorded reasons. Holding this change impermissible, ITAT declared the reassessment invalid and set it aside.
ITAT allowed the assessee's appeal and quashed the reassessment order passed u/s 147 r.w.s. 144B. The AO had reopened the assessment solely on the belief that income had escaped assessment by non-application of s.50C (capital gains on transfer of land/building). However, in the reassessment, no addition was made under s.50C; instead, the AO invoked s.43CA (business income on transfer of land/building held as stock-in-trade), which was never part of the recorded reasons. Holding this change impermissible, ITAT declared the reassessment invalid and set it aside.
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