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    <title>2019 (9) TMI 615 - BOMBAY HIGH COURT</title>
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    <description>Section 11(2)(a) of the Special Court Act was applied to scale down income-tax liability where the assessment was framed on a best judgment basis under section 144, the additions rested on uncertain factual material, and the resulting demand was found grossly disproportionate to the assets available with the Custodian. The Court also accepted that a practical nexus was enough between the applicants&#039; decretal amounts and the income assessed against the notified party because the monies paid had been credited to the notified party&#039;s account and formed part of the common pool of funds. Relief was therefore granted by directing proportionate release in favour of the applicants.</description>
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      <link>https://www.taxtmi.com/caselaws?id=385847</link>
      <description>Section 11(2)(a) of the Special Court Act was applied to scale down income-tax liability where the assessment was framed on a best judgment basis under section 144, the additions rested on uncertain factual material, and the resulting demand was found grossly disproportionate to the assets available with the Custodian. The Court also accepted that a practical nexus was enough between the applicants&#039; decretal amounts and the income assessed against the notified party because the monies paid had been credited to the notified party&#039;s account and formed part of the common pool of funds. Relief was therefore granted by directing proportionate release in favour of the applicants.</description>
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