Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
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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