Customs valuation and import permissibility conflict resolved: accepted enhancement of transaction value removes liability for confiscation and penalt...
Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
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The Tribunal examined multiple search-related assessment issues, including section 68 cash credits, section 69C unexplained expenditure, bogus purchases, stock discrepancy, employees' contribution disallowance, and section 153A jurisdiction. It held that primary evidence such as confirmations, PAN, returns and bank statements was sufficient for section 68, and the Revenue had to conduct independent verification; the source of source was not required on these facts. It also sustained only the profit element in disputed purchases, deleted a stock-difference addition after reconciliation and valuation defects, remanded one seized-noting issue for fresh verification, upheld disallowance of delayed employees' contribution, and rejected the challenge to assessments based on seized material.
The Tribunal examined multiple search-related assessment issues, including section 68 cash credits, section 69C unexplained expenditure, bogus purchases, stock discrepancy, employees' contribution disallowance, and section 153A jurisdiction. It held that primary evidence such as confirmations, PAN, returns and bank statements was sufficient for section 68, and the Revenue had to conduct independent verification; the source of source was not required on these facts. It also sustained only the profit element in disputed purchases, deleted a stock-difference addition after reconciliation and valuation defects, remanded one seized-noting issue for fresh verification, upheld disallowance of delayed employees' contribution, and rejected the challenge to assessments based on seized material.
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