Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
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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