Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
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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