Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Reassessment against a deceased assessee: procedural defect mandates fresh reassessment; nonresponsive petitioner may be treated as legal representati...
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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