Tax appeal allowed: AO exceeded s.144C DRP mandate by introducing new findings and recharacterising non-resident receipts as permanent establishment i...
Anonymized petitioner gets partial relief: bank guarantee quashed, PVC-coated fabric released under reduced conditions while valuation proceedings con...
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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