Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof...
ITAT upheld the reassessment notice because the record showed prior approval of the Principal Commissioner on the notice under section 148A(b), and both the notice and approval were within the statutory time limit, so the challenge on limitation and lack of approval failed. On disputed bogus purchases, the Tribunal held that invoices, ledgers and banking entries were not enough where Investigation Wing and GST material indicated accommodation entry suppliers and there were deficiencies in transport and purchase-to-sale linkage. It found that the existing factual examination was inadequate to sustain either full disallowance or a restriction to 15%, and restored the matter to the Assessing Officer for fresh verification and enquiries.
ITAT upheld the reassessment notice because the record showed prior approval of the Principal Commissioner on the notice under section 148A(b), and both the notice and approval were within the statutory time limit, so the challenge on limitation and lack of approval failed. On disputed bogus purchases, the Tribunal held that invoices, ledgers and banking entries were not enough where Investigation Wing and GST material indicated accommodation entry suppliers and there were deficiencies in transport and purchase-to-sale linkage. It found that the existing factual examination was inadequate to sustain either full disallowance or a restriction to 15%, and restored the matter to the Assessing Officer for fresh verification and enquiries.
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