Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
Reassessment initiated under an incorrect and non-operative PAN was treated as a jurisdictional defect, not a mere procedural lapse, because the assessee had disclosed the transactions under the correct PAN and the reply under section 148A was not considered before issuing notice; the proceedings were also held time-barred. On merits, cash deposits were accepted as business receipts where the books and explanation were unrebutted, and rejection of accounts solely for want of a tax audit was unjustified. The FDR investments were likewise explained from renewal of earlier deposits and the same business receipts, so the addition could not survive and double taxation of the same funds was impermissible.
Reassessment initiated under an incorrect and non-operative PAN was treated as a jurisdictional defect, not a mere procedural lapse, because the assessee had disclosed the transactions under the correct PAN and the reply under section 148A was not considered before issuing notice; the proceedings were also held time-barred. On merits, cash deposits were accepted as business receipts where the books and explanation were unrebutted, and rejection of accounts solely for want of a tax audit was unjustified. The FDR investments were likewise explained from renewal of earlier deposits and the same business receipts, so the addition could not survive and double taxation of the same funds was impermissible.
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