Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
A single show-cause notice or composite assessment order cannot validly cover more than one tax period once the annual return due date has been reached; each financial year must be adjudicated separately. Applying an earlier Division Bench view, the HC set aside the impugned Order in Original because it covered four financial years in one order. The matter was remitted for fresh proceedings year-wise, with liberty to initiate separate proceedings for each assessment year, and the intervening period was directed to be excluded for limitation. All other grounds of challenge were left open.
A single show-cause notice or composite assessment order cannot validly cover more than one tax period once the annual return due date has been reached; each financial year must be adjudicated separately. Applying an earlier Division Bench view, the HC set aside the impugned Order in Original because it covered four financial years in one order. The matter was remitted for fresh proceedings year-wise, with liberty to initiate separate proceedings for each assessment year, and the intervening period was directed to be excluded for limitation. All other grounds of challenge were left open.
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