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...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
ITAT held that reassessment initiated after three years from the end of AY 2017-18 could not be sustained where the alleged escaped income was only Rs. 5,00,000, because section 149(1)(b) applies only when the escaped income is, or is likely to be, Rs. 50,00,000 or more in the prescribed form. As that statutory threshold was not met, the sanction under section 151 was invalid and the notice under section 148 was bad in law, rendering the reassessment under section 147 liable to be quashed. The merits of the addition and the remaining grounds were left unadjudicated as academic.
ITAT held that reassessment initiated after three years from the end of AY 2017-18 could not be sustained where the alleged escaped income was only Rs. 5,00,000, because section 149(1)(b) applies only when the escaped income is, or is likely to be, Rs. 50,00,000 or more in the prescribed form. As that statutory threshold was not met, the sanction under section 151 was invalid and the notice under section 148 was bad in law, rendering the reassessment under section 147 liable to be quashed. The merits of the addition and the remaining grounds were left unadjudicated as academic.
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