Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Extended period of limitation unsustainable; allowable deductions for prompt payment discounts, pro rata recovery, freight and VAT led to demand being...
Additions based on documents seized in the case of another person must be brought within the reassessment framework under Explanation 2 to section 148, after recording the prescribed satisfaction and obtaining statutory approval; they cannot be made in a regular assessment under section 143(3). The ITAT held that the Assessing Officer's use of third-party search material without following that mandatory procedure rendered the assessment invalid. The assessment order was therefore quashed, and the remaining grounds became academic.
Additions based on documents seized in the case of another person must be brought within the reassessment framework under Explanation 2 to section 148, after recording the prescribed satisfaction and obtaining statutory approval; they cannot be made in a regular assessment under section 143(3). The ITAT held that the Assessing Officer's use of third-party search material without following that mandatory procedure rendered the assessment invalid. The assessment order was therefore quashed, and the remaining grounds became academic.
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