Composite residential flat exemption upheld where supplementary agreement merged adjoining units and additional evidence supported the taxpayer's inve...
Urgent interim relief exception permits commercial suit without pre-institution mediation where immediate disclosure and asset protection are genuinel...
For valid reassessment the assessing officer must record a belief based on objective, specific and reliable material that has a live nexus to escapement of income; reliance on unverified information from an investigation unit or on borrowed satisfaction reduces belief to mere suspicion and invalidates reopening. Independent application of mind and preliminary enquiries are required before issuing notices under reassessment provisions. Separately, mere inter company fund rotations and receipt of share application money do not automatically constitute taxable income or unexplained credits where documentary support (investors' financials, ITRs, bank statements, confirmations) shows capital receipts; treating such transactions as unexplained under the unexplained credit principle is unsustainable.
For valid reassessment the assessing officer must record a belief based on objective, specific and reliable material that has a live nexus to escapement of income; reliance on unverified information from an investigation unit or on borrowed satisfaction reduces belief to mere suspicion and invalidates reopening. Independent application of mind and preliminary enquiries are required before issuing notices under reassessment provisions. Separately, mere inter company fund rotations and receipt of share application money do not automatically constitute taxable income or unexplained credits where documentary support (investors' financials, ITRs, bank statements, confirmations) shows capital receipts; treating such transactions as unexplained under the unexplained credit principle is unsustainable.
Note: It is a system-generated summary and is for quick reference only.
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