Tax authority's substitution of projected figures with actuals overturned; original acquisition valuation upheld; transfer pricing issues remitted for...
Beneficial owner held liable for differential customs duty; royalties added under Rule 10(1)(c); confiscation, penalties under s.111(m), s.114A, s.112...
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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