Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Reopening under s.147 was held invalid because the recorded reasons did not demonstrate a clear, direct nexus between the stated transaction discrepancies and any escapement of income, rendering the belief speculative; accordingly, the reassessment was quashed. Independently, the s.68 addition for alleged unexplained credits was deleted as the taxpayer discharged the statutory onus by furnishing cogent documentary evidence establishing identity, creditworthiness, and genuineness of the credit, and the loan was also repaid; the appellate confirmation of the addition was set aside. - ITAT
Reopening under s.147 was held invalid because the recorded reasons did not demonstrate a clear, direct nexus between the stated transaction discrepancies and any escapement of income, rendering the belief speculative; accordingly, the reassessment was quashed. Independently, the s.68 addition for alleged unexplained credits was deleted as the taxpayer discharged the statutory onus by furnishing cogent documentary evidence establishing identity, creditworthiness, and genuineness of the credit, and the loan was also repaid; the appellate confirmation of the addition was set aside. - ITAT
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