Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Reopening after search was held time barred for the 2012-13 assessment as the notice under section 148 fell outside the ten year limitation and the reassessment was quashed. The note states that only the profit element of undisclosed 'on money' is taxable, and a uniform estimation rate of 10% was applied on the facts. Unaccounted profit is taxable in the year of execution of the sale deed (transfer), with ICDS III inapplicable. Issues of alleged negative cash balances were remitted to the AO for verification. Telescoping deletions under unexplained money were upheld where an assessed profit exceeded other applications, and a seized ledger corroborated a short term capital gain addition.
Reopening after search was held time barred for the 2012-13 assessment as the notice under section 148 fell outside the ten year limitation and the reassessment was quashed. The note states that only the profit element of undisclosed 'on money' is taxable, and a uniform estimation rate of 10% was applied on the facts. Unaccounted profit is taxable in the year of execution of the sale deed (transfer), with ICDS III inapplicable. Issues of alleged negative cash balances were remitted to the AO for verification. Telescoping deletions under unexplained money were upheld where an assessed profit exceeded other applications, and a seized ledger corroborated a short term capital gain addition.
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