Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
Benami property exclusion from the insolvency estate: Benami Act proceedings preclude IBC tribunals from reopening attachments or treating such assets...
Reopening of assessment was invalidated for lack of tangible material and the AO's independent application of mind; the notice under section 147/148 rested on 'borrowed satisfaction' from the investigation wing without requisite nexus or reasoned inference of escapement and therefore failed the four essential ingredients for reopening. On merits, share application monies treated as unexplained cash credits under section 68 were deleted: the assessee produced confirmations, bank statements and investors' audited accounts and sought summonses, and the Tribunal found the evidentiary onus discharged despite limited third party noncompliance.
Reopening of assessment was invalidated for lack of tangible material and the AO's independent application of mind; the notice under section 147/148 rested on 'borrowed satisfaction' from the investigation wing without requisite nexus or reasoned inference of escapement and therefore failed the four essential ingredients for reopening. On merits, share application monies treated as unexplained cash credits under section 68 were deleted: the assessee produced confirmations, bank statements and investors' audited accounts and sought summonses, and the Tribunal found the evidentiary onus discharged despite limited third party noncompliance.
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