Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
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In corporate assessments of unexplained share capital and share premium, documented traceability via ITR acknowledgments, PAN details and bank statements through legitimate channels is accorded greater evidentiary weight than the Assessing Officer's subjective "Test of Human Probability"; accordingly the addition was deleted. The ratio in NRA Iron & Steel is confined to phantom or nonexistent subscribers that cannot be traced; it does not apply where subscribers are verifiable and creditworthy. Revenue must prove a direct "live link" showing funds originated from the assessee's own coffers; absent contrary material, Tribunal factual findings upholding castiron documentary evidence prevail and no substantial question of law arises.
In corporate assessments of unexplained share capital and share premium, documented traceability via ITR acknowledgments, PAN details and bank statements through legitimate channels is accorded greater evidentiary weight than the Assessing Officer's subjective "Test of Human Probability"; accordingly the addition was deleted. The ratio in NRA Iron & Steel is confined to phantom or nonexistent subscribers that cannot be traced; it does not apply where subscribers are verifiable and creditworthy. Revenue must prove a direct "live link" showing funds originated from the assessee's own coffers; absent contrary material, Tribunal factual findings upholding castiron documentary evidence prevail and no substantial question of law arises.
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