The reassessment relied entirely on allegations arising from a search on another entity. The Tribunal ruled that additions cannot survive without independent evidence directly linking the assessee.
The issue was whether reassessment is valid when reasons for reopening are not placed on record. The Tribunal held that non-recording of reasons under Section 148(2) vitiates jurisdiction, rendering the reassessment void.
The Tribunal condoned a 506-day delay after accepting that the appeal was filed only when heavy penalty exposure created prosecution risk. The key takeaway is that bona fide reliance on legal advice and later developments can constitute sufficient cause for condonation.
The issue was whether third-party diaries and loose papers could establish receipt of unaccounted income. The Tribunal ruled that such papers, without authorship verification or corroboration, cannot fasten tax liability.
The Court examined whether a sanction lacking a DIN could sustain income-tax proceedings. It held such sanction invalid and set aside the consequential orders.
This ruling clarifies that an assessee can be treated as an agent of a non-resident only if income is received directly or indirectly for the NRI. In the absence of such receipt or business connection, representative assessment fails.
The Court examined whether a show-cause notice under Section 74 was issued by a competent authority. Limited protection was granted while permitting a response to the notice.
The Court examined a GST final intimation alleged to be issued without jurisdiction and statutory compliance. Interim protection was granted, restraining coercive action pending affidavits.
The Court set aside a GST demand that exceeded the amount proposed in the show-cause notice. The ruling reinforces the statutory cap under Section 75(7) on confirmed demands.
The Tribunal examined whether prior approval under Section 153D was granted after due application of mind. It held that mechanical and routine approval invalidates the assessment, rendering the search assessment void.
