Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
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Revision u/s 263 was held unsustainable because the AO had conducted independent enquiry, recorded third-party statements corroborated by the assessee's personnel, and adopted a plausible view accepting purchases as genuine; the revisional authority failed to specifically demonstrate how the assessment was both erroneous and prejudicial, resting mainly on suspicion and third-party cash withdrawals, so the revision order was set aside. On reassessment, addition for alleged bogus purchases of raw material was deleted as sales (including exports with statutory clearances) were accepted, payments were through banking channels, stock/yield were not doubted, supplier confirmations and documents supported procurement, and the "round-tripping" inference lacked year-specific material; the deletion was upheld against the revenue. - ITAT
Revision u/s 263 was held unsustainable because the AO had conducted independent enquiry, recorded third-party statements corroborated by the assessee's personnel, and adopted a plausible view accepting purchases as genuine; the revisional authority failed to specifically demonstrate how the assessment was both erroneous and prejudicial, resting mainly on suspicion and third-party cash withdrawals, so the revision order was set aside. On reassessment, addition for alleged bogus purchases of raw material was deleted as sales (including exports with statutory clearances) were accepted, payments were through banking channels, stock/yield were not doubted, supplier confirmations and documents supported procurement, and the "round-tripping" inference lacked year-specific material; the deletion was upheld against the revenue. - ITAT
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