Reversal of input tax credit in proportion to exempt supply: specificity of show-cause notice required; order set aside, fresh proceedings allowed wit...
Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
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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