Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
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Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
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An inchoate agreement to sell, lacking execution by both parties and showing patent ambiguity, could not be treated as conclusive evidence of receipt of unaccounted on-money. The Tribunal held that an admission must be clear, unambiguous and unconditional, and that the seized document, without material particulars such as witness details or the drafter's identity and without the beneficiary's participation, did not justify an inference of undisclosed cash receipts. The additions based on that document were therefore deleted, and the consequential penalty was also deleted.
An inchoate agreement to sell, lacking execution by both parties and showing patent ambiguity, could not be treated as conclusive evidence of receipt of unaccounted on-money. The Tribunal held that an admission must be clear, unambiguous and unconditional, and that the seized document, without material particulars such as witness details or the drafter's identity and without the beneficiary's participation, did not justify an inference of undisclosed cash receipts. The additions based on that document were therefore deleted, and the consequential penalty was also deleted.
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