Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Customs jurisdiction defined for Principal Commissioner, Vishakhapatnam, covering specified ports, districts and India's adjacent EEZ; effective on pu...
Assessment jurisdiction under search provisions cannot be assumed for unabated years based on third-party digital chats; the third-party WhatsApp material was unrelated, post-facto and not incriminating, consequently the addition was deleted. The revenue bears the onus to prove unrecorded consideration, and reliance on uncorroborated digital chats or 'dumb documents' is impermissible, so the on-money addition failed on merits. Extrapolating modus operandi or materials from another entity or assessment year to make additions is legally unsound; such additions were deleted. Alleged penny stock contrivances lacking incriminating search material and documentary proof were likewise disallowed and revenue appeals dismissed.
Assessment jurisdiction under search provisions cannot be assumed for unabated years based on third-party digital chats; the third-party WhatsApp material was unrelated, post-facto and not incriminating, consequently the addition was deleted. The revenue bears the onus to prove unrecorded consideration, and reliance on uncorroborated digital chats or 'dumb documents' is impermissible, so the on-money addition failed on merits. Extrapolating modus operandi or materials from another entity or assessment year to make additions is legally unsound; such additions were deleted. Alleged penny stock contrivances lacking incriminating search material and documentary proof were likewise disallowed and revenue appeals dismissed.
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