Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Reopening under section 147 hinged on whether the AO had independent "reasons to believe" or merely adopted borrowed satisfaction from the Insight Portal; the Tribunal found no nexus between materials on record and the information relied upon, holding the AO failed to apply independent mind, so the re-opening was invalid-reassessment order under section 147 quashed. Because the foundational notice was quashed, the Tribunal declined to decide the substantive allegation of bogus long-term capital gains, resulting in a decision for the assessee. - ITAT
Reopening under section 147 hinged on whether the AO had independent "reasons to believe" or merely adopted borrowed satisfaction from the Insight Portal; the Tribunal found no nexus between materials on record and the information relied upon, holding the AO failed to apply independent mind, so the re-opening was invalid-reassessment order under section 147 quashed. Because the foundational notice was quashed, the Tribunal declined to decide the substantive allegation of bogus long-term capital gains, resulting in a decision for the assessee. - ITAT
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