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...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Section 270AA gives finality where an assessee accepts the assessment without appeal and secures immunity from penalty and prosecution; a later section 154 rectification cannot be used to substantially rewrite the assessment or change its tax consequence, so the rectification order was without jurisdiction. An ad hoc disallowance of expenditure already recorded in the books and reflected in the accounts is not unexplained expenditure under section 69C; it is only an estimated disallowance for want of verification, so section 115BBE could not be applied in rectification proceedings. The Tribunal quashed both the rectification order and the appellate order affirming it.
Section 270AA gives finality where an assessee accepts the assessment without appeal and secures immunity from penalty and prosecution; a later section 154 rectification cannot be used to substantially rewrite the assessment or change its tax consequence, so the rectification order was without jurisdiction. An ad hoc disallowance of expenditure already recorded in the books and reflected in the accounts is not unexplained expenditure under section 69C; it is only an estimated disallowance for want of verification, so section 115BBE could not be applied in rectification proceedings. The Tribunal quashed both the rectification order and the appellate order affirming it.
Note: It is a system-generated summary and is for quick reference only.