Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Invocation of the tax search-transfer provision cannot rest on material obtained from public-domain sources or other external records that were not part of the seized documents; reliance on such material defeats the required nexus to seized incriminating material and renders jurisdictional exercise invalid. Where incriminating material "relating to" a third person is transmitted, it is mandatory that the Assessing Officer of the searched person record and communicate a satisfaction note before the jurisdictional Assessing Officer may proceed; proceedings initiated without that satisfaction note are without jurisdiction and unsustainable. Notices founded on external/public material or lacking the mandatory satisfaction note were quashed.
Invocation of the tax search-transfer provision cannot rest on material obtained from public-domain sources or other external records that were not part of the seized documents; reliance on such material defeats the required nexus to seized incriminating material and renders jurisdictional exercise invalid. Where incriminating material "relating to" a third person is transmitted, it is mandatory that the Assessing Officer of the searched person record and communicate a satisfaction note before the jurisdictional Assessing Officer may proceed; proceedings initiated without that satisfaction note are without jurisdiction and unsustainable. Notices founded on external/public material or lacking the mandatory satisfaction note were quashed.
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