Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Reassessment was quashed because the recorded reasons suffered from fundamental defects: no proper approval in the prescribed form, absence of signature on sanction, and material factual errors in the basis for reopening. The assessing officer's later attempt to substitute fresh reasons was not permitted under section 147, and the alternative reasons still rested on suspicion, third-party information about the assessee's husband, and no independent tangible material showing escapement in the assessee's own case. The Tribunal held this amounted only to a reason to suspect, not a valid reason to believe. Cross-objections were also rejected as time-barred, since they were filed 27 days late without any condonation request.
Reassessment was quashed because the recorded reasons suffered from fundamental defects: no proper approval in the prescribed form, absence of signature on sanction, and material factual errors in the basis for reopening. The assessing officer's later attempt to substitute fresh reasons was not permitted under section 147, and the alternative reasons still rested on suspicion, third-party information about the assessee's husband, and no independent tangible material showing escapement in the assessee's own case. The Tribunal held this amounted only to a reason to suspect, not a valid reason to believe. Cross-objections were also rejected as time-barred, since they were filed 27 days late without any condonation request.
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