Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Customs jurisdiction defined for Principal Commissioner, Vishakhapatnam, covering specified ports, districts and India's adjacent EEZ; effective on pu...
Validity of reassessment under section 147 turned on whether the AO acted on tangible information and applied independent mind rather than on borrowed satisfaction; the Tribunal held that specific information about substantial cash capital introduction, considered against low returned income and material on record, satisfied the prima facie belief threshold required for reopening. The Tribunal further upheld treating the cash capital introduction as unexplained investment under section 69, placing onus on the assessee to prove the source. Conclusion: reassessment initiation and the addition under section 69 were sustained and the appeal was dismissed by ITAT.
Validity of reassessment under section 147 turned on whether the AO acted on tangible information and applied independent mind rather than on borrowed satisfaction; the Tribunal held that specific information about substantial cash capital introduction, considered against low returned income and material on record, satisfied the prima facie belief threshold required for reopening. The Tribunal further upheld treating the cash capital introduction as unexplained investment under section 69, placing onus on the assessee to prove the source. Conclusion: reassessment initiation and the addition under section 69 were sustained and the appeal was dismissed by ITAT.
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