Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
ITAT held that rectification under section 154 cannot be used to recharacterise survey disclosure accepted in scrutiny assessment as business income into unexplained money under section 69A and taxed under section 115BBE. The amount had been stated during survey as on-money receipts from business activity, credited in the regular books, and accepted in the original section 143(3) assessment as business income. Because changing its character would require fresh factual appraisal and a new determination on section 69A, the issue was debatable and outside the limited scope of rectification. The rectification order was therefore unsustainable.
ITAT held that rectification under section 154 cannot be used to recharacterise survey disclosure accepted in scrutiny assessment as business income into unexplained money under section 69A and taxed under section 115BBE. The amount had been stated during survey as on-money receipts from business activity, credited in the regular books, and accepted in the original section 143(3) assessment as business income. Because changing its character would require fresh factual appraisal and a new determination on section 69A, the issue was debatable and outside the limited scope of rectification. The rectification order was therefore unsustainable.
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