Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
In search-linked reassessment under the post-01.04.2021 regime, a search, a post-assessment statement, and field verification were treated as fresh tangible material supporting a reasoned belief of escapement; the challenge based on change of opinion and absence of incriminating material was rejected. For the unexplained cash credit issue, the Tribunal found that the Revenue relied substantially on an adverse third-party statement that was uncorroborated, while the assessee was denied cross-examination, amounting to a serious breach of natural justice. It also noted that Section 68 applies only to credits received in the relevant year, not opening balances, and remitted the additions for fresh adjudication after cross-examination and proper inquiry.
In search-linked reassessment under the post-01.04.2021 regime, a search, a post-assessment statement, and field verification were treated as fresh tangible material supporting a reasoned belief of escapement; the challenge based on change of opinion and absence of incriminating material was rejected. For the unexplained cash credit issue, the Tribunal found that the Revenue relied substantially on an adverse third-party statement that was uncorroborated, while the assessee was denied cross-examination, amounting to a serious breach of natural justice. It also noted that Section 68 applies only to credits received in the relevant year, not opening balances, and remitted the additions for fresh adjudication after cross-examination and proper inquiry.
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