Assessment time-barred u/s 153 due to missing competent-authority reference for Singapore exchange of information; assessment disallowed as barred by ...
Imported menthol-scented sweet supari classification dispute: seizure quashed, release for home consumption subject to duty bond; bank guarantee refus...
CKD/SKD air-conditioner components classifiable with finished units by essential character; prior advance ruling extended three years, FTA benefits po...
Scope of judicial review under Article 226: supervisory, not appellate; factual reappraisal barred, challenge dismissed; insolvency professional dutie...
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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