Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Threshold for allottee-initiated insolvency petitions in leasehold real estate upheld; petition admitted after possession letters deemed legally ineff...
Contravention of foreign exchange rules in crossborder diamond payments; appellate tribunal reduces one appellant's penalty for delay and proportional...
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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