Interest on Wrongful Input Tax Credit is mandatory where excess transitional credit was retained and later reversed, and related objections were rejec...
Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
Limitation for search assessments under a joint warrant was required to be computed person-wise under section 153B read with section 292CC, so the last panchanama in another person's case could not extend time for the assessee; the assessments completed after the statutory period were quashed. Additions based on third-party emails, loose sheets, WhatsApp chats and other electronic material were deleted because the Department failed to prove ownership, nexus, fund flow or corroboration. Estimated commission on alleged bogus sub-contracts and cash-repass theories also failed for want of supporting evidence and cross-examination. Deduction under section 80IA(4) for infrastructure work was upheld on binding precedent.
Limitation for search assessments under a joint warrant was required to be computed person-wise under section 153B read with section 292CC, so the last panchanama in another person's case could not extend time for the assessee; the assessments completed after the statutory period were quashed. Additions based on third-party emails, loose sheets, WhatsApp chats and other electronic material were deleted because the Department failed to prove ownership, nexus, fund flow or corroboration. Estimated commission on alleged bogus sub-contracts and cash-repass theories also failed for want of supporting evidence and cross-examination. Deduction under section 80IA(4) for infrastructure work was upheld on binding precedent.
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