Classification of imported salvaged shaft pieces as ship parts confirmed, reassessment time-barred and appeal allowed restoring original classificatio...
Scope of intermediary status for data hosting services: tribunal finds provider not intermediary, services exported and not taxable, limited remand on...
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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