Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Under the PBPT Act, attachment can continue only against benami property held by a benamidar or beneficial owner; property cannot be attached merely because its owner is treated as an abettor unless the property itself is found to be benami. The Tribunal noted that the appellant had been proceeded against as beneficial owner initially, but the adjudication position shifted to Smt. Shital Soni as beneficial owner and the appellant as only an abettor. As there was no specific finding that the appellant's attached properties were benami, continuation of attachment was unsustainable. The attachment was set aside to that extent, while the appellant's exposure to consequences for abetment was left unaffected.
Under the PBPT Act, attachment can continue only against benami property held by a benamidar or beneficial owner; property cannot be attached merely because its owner is treated as an abettor unless the property itself is found to be benami. The Tribunal noted that the appellant had been proceeded against as beneficial owner initially, but the adjudication position shifted to Smt. Shital Soni as beneficial owner and the appellant as only an abettor. As there was no specific finding that the appellant's attached properties were benami, continuation of attachment was unsustainable. The attachment was set aside to that extent, while the appellant's exposure to consequences for abetment was left unaffected.
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