Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Reopening of assessment beyond four years was held invalid because the assessee had disclosed complete books, audited financials, and ledgers for machinery rent, purchases, and carriage expenses during the original scrutiny, and the AO had examined cash payments and made an ad hoc disallowance after applying mind. The alleged Section 68 discrepancy in an unsecured loan ledger was found to be a transparent accounting misposting of a bank transfer by a partner, with no impact on cash balance or total liabilities, later rectified. In the absence of any fresh tangible material, the reopening amounted to a mere change of opinion barred by law; notice under Section 148 was quashed and the appeal was allowed - ITAT
Reopening of assessment beyond four years was held invalid because the assessee had disclosed complete books, audited financials, and ledgers for machinery rent, purchases, and carriage expenses during the original scrutiny, and the AO had examined cash payments and made an ad hoc disallowance after applying mind. The alleged Section 68 discrepancy in an unsecured loan ledger was found to be a transparent accounting misposting of a bank transfer by a partner, with no impact on cash balance or total liabilities, later rectified. In the absence of any fresh tangible material, the reopening amounted to a mere change of opinion barred by law; notice under Section 148 was quashed and the appeal was allowed - ITAT
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