Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Extended period of limitation unsustainable; allowable deductions for prompt payment discounts, pro rata recovery, freight and VAT led to demand being...
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Bank account credits were held to originate from a third party and the account functioned as a conduit; therefore the credited sums were not treated as the assessee's unexplained income. The Tribunal relied on bank statements, deposit-withdrawal patterns and admissions to conclude the assessee permitted use of his account for Shree Impex, with a different principal beneficiary. Because the assessee facilitated transactions and obtained a limited benefit, the Tribunal treated the correct tax consequence as assessable commission income and directed assessment of commission on the turnover routed through the account, applying the same reasoning to other identical assessment years.
Bank account credits were held to originate from a third party and the account functioned as a conduit; therefore the credited sums were not treated as the assessee's unexplained income. The Tribunal relied on bank statements, deposit-withdrawal patterns and admissions to conclude the assessee permitted use of his account for Shree Impex, with a different principal beneficiary. Because the assessee facilitated transactions and obtained a limited benefit, the Tribunal treated the correct tax consequence as assessable commission income and directed assessment of commission on the turnover routed through the account, applying the same reasoning to other identical assessment years.
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