Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Seized loose sheets, Rojmel, MITI and related digital records were held to have evidentiary value where the Assessing Officer had correlated them with each other and the assessees showed no specific defect or alternative explanation; retraction affidavits by employees did not neutralise the seized material. The Tribunal also rejected the claim that all entries were mere facilitation passes, holding that some reflected the assessees' own unaccounted sales and cash receipts. Profit, however, had to be estimated on a rational basis rather than guesswork: 4% was applied to undisclosed own transactions and cash sales, and 1.5% to facilitation-based transactions in the LLP matter, while 4% was applied to unaccounted cash sales of the trading concerns.
Seized loose sheets, Rojmel, MITI and related digital records were held to have evidentiary value where the Assessing Officer had correlated them with each other and the assessees showed no specific defect or alternative explanation; retraction affidavits by employees did not neutralise the seized material. The Tribunal also rejected the claim that all entries were mere facilitation passes, holding that some reflected the assessees' own unaccounted sales and cash receipts. Profit, however, had to be estimated on a rational basis rather than guesswork: 4% was applied to undisclosed own transactions and cash sales, and 1.5% to facilitation-based transactions in the LLP matter, while 4% was applied to unaccounted cash sales of the trading concerns.
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