Admissibility of inquiry statements and electronic printouts in customs adjudication requires witness examination and cross-examination before relianc...
Money laundering property attachment and third-party encumbrance rights clarified; prior bona fide interests enforceable before confiscation, appeals ...
Validity of reopening was examined with emphasis on limitation and newly inserted procedural safeguards; since the notice was time-barred the reopening was quashed. Taxation of undisclosed on-money receipts was assessed by estimating profit element; in absence of records the appellate authority adopted a 17% profit estimate on receipts, and allowed telescoping credit for income voluntarily declared under the disclosure scheme, treating declaration as sufficient without source specification. Additions on account of unsecured loans were rejected where the taxpayer proved identity and creditworthiness of lenders with confirmations, PANs, bank statements and subsequent bank repayments; source-of-source proof was not required and acceptance of repayment precluded current year addition.
Validity of reopening was examined with emphasis on limitation and newly inserted procedural safeguards; since the notice was time-barred the reopening was quashed. Taxation of undisclosed on-money receipts was assessed by estimating profit element; in absence of records the appellate authority adopted a 17% profit estimate on receipts, and allowed telescoping credit for income voluntarily declared under the disclosure scheme, treating declaration as sufficient without source specification. Additions on account of unsecured loans were rejected where the taxpayer proved identity and creditworthiness of lenders with confirmations, PANs, bank statements and subsequent bank repayments; source-of-source proof was not required and acceptance of repayment precluded current year addition.
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