Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Protective additions based on seized books were set aside where corresponding substantive assessments against a third party were quashed for lack of jurisdiction and the assessing authorities had not independently examined seized material or the assessee's statements; matters remitted to the AO for fresh adjudication. The limitation challenge failed because contemporaneous records showed exchange-of-information references bringing Explanation 1(x) to section 153 into play, so the assessment was within the extended period. Approval under section 153D was held administrative; absence of elaborate reasons did not rebut the presumption of application of mind. Telescoping of admitted undisclosed income against seized cash was permitted, and complex quantification issues were remitted for recomputation with opportunity to the assessee.
Protective additions based on seized books were set aside where corresponding substantive assessments against a third party were quashed for lack of jurisdiction and the assessing authorities had not independently examined seized material or the assessee's statements; matters remitted to the AO for fresh adjudication. The limitation challenge failed because contemporaneous records showed exchange-of-information references bringing Explanation 1(x) to section 153 into play, so the assessment was within the extended period. Approval under section 153D was held administrative; absence of elaborate reasons did not rebut the presumption of application of mind. Telescoping of admitted undisclosed income against seized cash was permitted, and complex quantification issues were remitted for recomputation with opportunity to the assessee.
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