Interest on Wrongful Input Tax Credit is mandatory where excess transitional credit was retained and later reversed, and related objections were rejec...
Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
Reassessment was challenged on the validity of "reasons to believe" and the requirement of a live link between material and alleged escapement of income. The recorded reasons were internally contradictory, alternately stating that no return was filed and that declared income did not match cash deposits, showing uncertainty on foundational facts. The AO relied merely on AIR data of cash deposits without any independent analysis or tangible material explaining the nature of transactions or connecting deposits to undisclosed income, rendering the reasons vague and lacking rational nexus. Consequently, the reassessment initiation was held invalid and the assessee's ground was allowed - ITAT
Reassessment was challenged on the validity of "reasons to believe" and the requirement of a live link between material and alleged escapement of income. The recorded reasons were internally contradictory, alternately stating that no return was filed and that declared income did not match cash deposits, showing uncertainty on foundational facts. The AO relied merely on AIR data of cash deposits without any independent analysis or tangible material explaining the nature of transactions or connecting deposits to undisclosed income, rendering the reasons vague and lacking rational nexus. Consequently, the reassessment initiation was held invalid and the assessee's ground was allowed - ITAT
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