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...
Reopening beyond four years after an assessment under section 143(3) was invalid because the recorded reasons did not allege that the assessee had failed to disclose fully and truly all material facts. The reassessment was initiated on Investigation Wing information about client code modification, but the relevant transactions and profit were already reflected in the contract notes and return, indicating no disclosed fraud or new material. The Tribunal treated the exercise as a mere change of opinion, noted that only a gist of reasons was supplied, the Investigation Wing report was not furnished, and no sanction under section 151 was produced. On these cumulative grounds, the reassessment was held illegal.
Reopening beyond four years after an assessment under section 143(3) was invalid because the recorded reasons did not allege that the assessee had failed to disclose fully and truly all material facts. The reassessment was initiated on Investigation Wing information about client code modification, but the relevant transactions and profit were already reflected in the contract notes and return, indicating no disclosed fraud or new material. The Tribunal treated the exercise as a mere change of opinion, noted that only a gist of reasons was supplied, the Investigation Wing report was not furnished, and no sanction under section 151 was produced. On these cumulative grounds, the reassessment was held illegal.
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