Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
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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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