Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
The Tribunal held that the statutory one-month timeline under section 148A(d) remains mandatory and is not extended by the broader surviving-period principle under section 148; the orders for AYs 2013-14 and 2014-15 were therefore time-barred and the consequential reassessment notices and orders were quashed. It further held that where action was founded solely on third-party search material, sections 153A/153C constituted the special route and general reassessment or assessment provisions could not be invoked without the required satisfaction note; the proceedings for AYs 2013-14, 2014-15 and 2020-21 were quashed on that ground. On merits, additions for accommodation entries, bank credits and duplicate loan credits were deleted because the sales and receipts were supported by records, bank statements are not books of account, and no objective inquiry or cash trail was shown.
The Tribunal held that the statutory one-month timeline under section 148A(d) remains mandatory and is not extended by the broader surviving-period principle under section 148; the orders for AYs 2013-14 and 2014-15 were therefore time-barred and the consequential reassessment notices and orders were quashed. It further held that where action was founded solely on third-party search material, sections 153A/153C constituted the special route and general reassessment or assessment provisions could not be invoked without the required satisfaction note; the proceedings for AYs 2013-14, 2014-15 and 2020-21 were quashed on that ground. On merits, additions for accommodation entries, bank credits and duplicate loan credits were deleted because the sales and receipts were supported by records, bank statements are not books of account, and no objective inquiry or cash trail was shown.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
