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...
Reopening after four years was invalid because the recorded reasons did not a failure by the assessee to fully and truly disclose material facts in the original scrutiny assessment. The AO had already sought details of unsecured loans and the assessee had furnished confirmations before assessment under Section 143(3) was completed without addition on that issue. The reasons for reopening merely referred to survey information about bogus unsecured loans from shell companies, but did not identify the loans, entities, or connecting material. Such vague reasons could not be supplemented later through objections, a rejection order, or a subsequent notice. The Section 148 notice was quashed.
Reopening after four years was invalid because the recorded reasons did not a failure by the assessee to fully and truly disclose material facts in the original scrutiny assessment. The AO had already sought details of unsecured loans and the assessee had furnished confirmations before assessment under Section 143(3) was completed without addition on that issue. The reasons for reopening merely referred to survey information about bogus unsecured loans from shell companies, but did not identify the loans, entities, or connecting material. Such vague reasons could not be supplemented later through objections, a rejection order, or a subsequent notice. The Section 148 notice was quashed.
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