Section 153C requires person-specific search authority and year-specific incriminating material for unabated assessments while preventing unsupported ...
Equivalent-value attachment can reach pre-existing assets, but jointly owned property remains protected beyond the accused's attributable proceeds of ...
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Reassessment initiated on departmental information flagged through the Insight Portal remains valid where the Assessing Officer independently confronts the taxpayer with the information, considers the response, passes an order under section 148A(d), and then issues notice under section 148. Such information may provide a starting point for enquiry without constituting borrowed satisfaction. However, sale proceeds from shares cannot be treated as unexplained accommodation entries merely on investigation allegations or suspicion where broker transactions, demat records, contract notes and banking channels remain undisputed, and no independent corroboration, cash trail, or link to an entry provider is established. The reassessment survived, but the share-sale addition was deleted.
Reassessment initiated on departmental information flagged through the Insight Portal remains valid where the Assessing Officer independently confronts the taxpayer with the information, considers the response, passes an order under section 148A(d), and then issues notice under section 148. Such information may provide a starting point for enquiry without constituting borrowed satisfaction. However, sale proceeds from shares cannot be treated as unexplained accommodation entries merely on investigation allegations or suspicion where broker transactions, demat records, contract notes and banking channels remain undisputed, and no independent corroboration, cash trail, or link to an entry provider is established. The reassessment survived, but the share-sale addition was deleted.
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