Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Reopening under Section 148 based on search material requires prima facie evidence showing a live link between the seized document and the assessee; the expressions "pertains to" and "relates to" cannot be read in vacuum. Here, the loose paper predated the assessee's purchase by nearly two years, did not name him, and the broker's statement did not refer to him or establish any connection with the named broker. The alleged on-money inference rested only on external matching of survey details, which was too vague and disconnected to satisfy the jurisdictional threshold. The writ petition was allowed and the reopening notices were quashed.
Reopening under Section 148 based on search material requires prima facie evidence showing a live link between the seized document and the assessee; the expressions "pertains to" and "relates to" cannot be read in vacuum. Here, the loose paper predated the assessee's purchase by nearly two years, did not name him, and the broker's statement did not refer to him or establish any connection with the named broker. The alleged on-money inference rested only on external matching of survey details, which was too vague and disconnected to satisfy the jurisdictional threshold. The writ petition was allowed and the reopening notices were quashed.
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