Reversal of input tax credit in proportion to exempt supply: specificity of show-cause notice required; order set aside, fresh proceedings allowed wit...
Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
A jurisdictional challenge to reassessment under section 147, raised for the first time in cross-objection on the footing that section 153C should have applied, was not entertained because it required fresh factual inquiry beyond the existing appellate record and no such challenge had been raised before the first appellate authority. The tribunal also upheld best judgment estimation of commission income from accommodation entries, holding that the appellate authority could not replace the Assessing Officer's estimate of 2% with 0.5% without identifying any evidentiary or legal infirmity in the original estimate. The assessee's cross-objections were dismissed and the additions were restored.
A jurisdictional challenge to reassessment under section 147, raised for the first time in cross-objection on the footing that section 153C should have applied, was not entertained because it required fresh factual inquiry beyond the existing appellate record and no such challenge had been raised before the first appellate authority. The tribunal also upheld best judgment estimation of commission income from accommodation entries, holding that the appellate authority could not replace the Assessing Officer's estimate of 2% with 0.5% without identifying any evidentiary or legal infirmity in the original estimate. The assessee's cross-objections were dismissed and the additions were restored.
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