Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
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The article addresses the legal infirmity of tax additions founded solely on digital ledger entries seized from a third party (Hazir Johri software). It states the statutory presumption applicable to a searched person does not extend to third parties (JBL), and ledger entries without contemporaneous corroboration (bills, invoices, vouchers, stock records) or exclusive linkage to the assessee are insufficient to sustain assessments. Applying this principle, peak credit and deemed unexplained money/profit additions based on such third party software entries and an employee statement were treated as conjectural and deleted; the appeals were allowed for the relevant years.
The article addresses the legal infirmity of tax additions founded solely on digital ledger entries seized from a third party (Hazir Johri software). It states the statutory presumption applicable to a searched person does not extend to third parties (JBL), and ledger entries without contemporaneous corroboration (bills, invoices, vouchers, stock records) or exclusive linkage to the assessee are insufficient to sustain assessments. Applying this principle, peak credit and deemed unexplained money/profit additions based on such third party software entries and an employee statement were treated as conjectural and deleted; the appeals were allowed for the relevant years.
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