Residential waste collection classification under SAC 999423 defeats composite-supply exemption where facilitating goods are not transferred to the lo...
Condonation of delay permits statutory appeal restoration where inadequate service explanation prevented consideration of reassessment and taxable-inc...
Limitation in customs appeals permits exclusion for bona fide refund proceedings, enabling restoration of Bill of Entry assessment challenges on merit...
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Reassessment under section 147 cannot be sustained where the income forming the recorded basis for reopening is not ultimately added. The Tribunal applied the binding principle that "and also" is conjunctive, so the Assessing Officer must first assess or reassess the escaped income identified in the recorded reasons before bringing in any other issue. Here, the reopening was based solely on alleged unexplained cash deposits during the demonetisation period, but that issue did not survive in reassessment. The resulting disallowance of interest expenditure on a different footing was therefore held to be unsustainable and deleted.
Reassessment under section 147 cannot be sustained where the income forming the recorded basis for reopening is not ultimately added. The Tribunal applied the binding principle that "and also" is conjunctive, so the Assessing Officer must first assess or reassess the escaped income identified in the recorded reasons before bringing in any other issue. Here, the reopening was based solely on alleged unexplained cash deposits during the demonetisation period, but that issue did not survive in reassessment. The resulting disallowance of interest expenditure on a different footing was therefore held to be unsustainable and deleted.
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