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...
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Invocation of jurisdiction under section 153C based solely on electronic material seized from third-party premises was held invalid because the seized account books contained no indicia linking them to the assessee; statutory presumptions operate in favour of the searched person and were not rebutted. Entries in third-party private notings were treated as "dumb documents" absent independent, corroborative evidence tying them to the assessee, and witness retraction undermined testimonial support. Consequently the AO's satisfaction under section 153C was held to be without jurisdiction and the assessment order was quashed.
Invocation of jurisdiction under section 153C based solely on electronic material seized from third-party premises was held invalid because the seized account books contained no indicia linking them to the assessee; statutory presumptions operate in favour of the searched person and were not rebutted. Entries in third-party private notings were treated as "dumb documents" absent independent, corroborative evidence tying them to the assessee, and witness retraction undermined testimonial support. Consequently the AO's satisfaction under section 153C was held to be without jurisdiction and the assessment order was quashed.
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