Unlawful outward remittances via Hawala using proforma invoices and electronic records proved; documents admitted, directors penalised, penalties redu...
Attachment of equivalent-value properties as proceeds of crime upheld; preventive attachment order and confirmation sustained; no independent ED reinv...
Broker trading-system "technical glitch" redefinition and narrowed incident-reporting regime for large IBT/STWT brokers requiring 2-hr notice and 14-w...
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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