Misdeclaration of quantity rejected where supplier evidence established counting errors, so reassessment, confiscation and redemption fine were set as...
Admissibility of electronic evidence controls valuation and penalty exposure; non compliant e records and statements nullify revaluation and penalties...
Reopening of assessment was quashed where the AO relied uncritically on AIR information without independent application of mind; the statutory test requires information with a direct nexus to form a belief that income escaped assessment, and treating transmission as conclusive or assuming return was not filed vitiated the formation of belief. The Addl. CIT's approval was held mechanical and based on incomplete facts, and the appellate tribunal upheld CIT(A)'s decision to quash the reopening, deciding against the revenue.
Reopening of assessment was quashed where the AO relied uncritically on AIR information without independent application of mind; the statutory test requires information with a direct nexus to form a belief that income escaped assessment, and treating transmission as conclusive or assuming return was not filed vitiated the formation of belief. The Addl. CIT's approval was held mechanical and based on incomplete facts, and the appellate tribunal upheld CIT(A)'s decision to quash the reopening, deciding against the revenue.
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