Centralised assessment transfers after searches coordinate connected investigations without finally determining the assessee's tax liability or assess...
Unsigned third-party records cannot establish on-money payments without corroboration and cross-examination, requiring deletion of the related additio...
Section 127 transfer of assessment following a search...
Centralised assessment transfers after searches coordinate connected investigations without finally determining the assessee's tax liability or assessment merits.
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Section 127 transfer of assessment following a search centralises proceedings involving entities connected with the investigation; it does not finally determine tax liability. Where an assessee's name emerges in search material, coordinated investigation and centralised assessment may justify transfer to a Central Circle. The assessee remains entitled to receive relevant material during assessment and to contest the matter on merits. Transfer is not arbitrary or prejudicial merely because assessment is moved where centralisation is required for coordinated investigation.
Section 127 transfer of assessment following a search centralises proceedings involving entities connected with the investigation; it does not finally determine tax liability. Where an assessee's name emerges in search material, coordinated investigation and centralised assessment may justify transfer to a Central Circle. The assessee remains entitled to receive relevant material during assessment and to contest the matter on merits. Transfer is not arbitrary or prejudicial merely because assessment is moved where centralisation is required for coordinated investigation.
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