Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Under CBDT Instruction No. 1/2011, metro corporate returns up to the prescribed income limit remained with the ITO, while only higher-value cases fell within ACIT/DCIT jurisdiction. Because the assessee's returned income and income assessed under section 143(3) were both below that limit, the ACIT lacked monetary jurisdiction to issue the section 148 notice. The Tribunal treated this defect as going to the validity of the jurisdictional notice itself, held the notice invalid, and quashed the reassessment order as consequentially unsustainable.
Under CBDT Instruction No. 1/2011, metro corporate returns up to the prescribed income limit remained with the ITO, while only higher-value cases fell within ACIT/DCIT jurisdiction. Because the assessee's returned income and income assessed under section 143(3) were both below that limit, the ACIT lacked monetary jurisdiction to issue the section 148 notice. The Tribunal treated this defect as going to the validity of the jurisdictional notice itself, held the notice invalid, and quashed the reassessment order as consequentially unsustainable.
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