While sales proceeds were claimed as the source, unexplained cash receipts appeared in the cash book. The Tribunal directed the Assessing Officer to re-examine deposits after detailed verification of records.
The court held that bank account attachment under GST cannot continue beyond one year without renewal. Failure to issue a fresh order rendered the attachment illegal.
Where capital subsidy was not received in the relevant year and no addition followed, reopening lacked basis. Mechanical reliance on audit objections was held unlawful.
The issue was whether a seized loose paper alone can justify an on-money addition under section 69. ITAT held that without independent corroboration, such addition cannot be sustained.
The law mandates strict adherence to the notice’s grounds and amounts. Any enhancement or new basis at adjudication violates natural justice and the CGST Act.
Expanded grounds for cancellation now include legal non-compliance and incorrect disclosures. Trusts must treat accuracy and governance as mission-critical.
Objects benefiting specific communities or allowing overseas application of funds invite rejection. The ruling focus is on deed language, not intent.
The order clarifies that filing an incorrect statutory e-form attracts penalties even if the mistake is later admitted and rectified. Administrative correction does not erase the original contravention under the Companies Act.
The Tribunal examined whether a single, consolidated satisfaction note for multiple assessment years meets the requirement of Section 153C. It held that such consolidated recording vitiates jurisdiction, rendering the search assessments void.
The issue is high liquidity and funding costs under gross settlement for FPIs. The proposal allows limited netting to improve efficiency while preserving market safeguards.
