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...
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Absence of a Document Identification Number in a section 153D approval did not invalidate the assessment, because the curative rule was read to cover assessment proceedings and connected communications, not only the final order. For the search assessment, the Tribunal held that A.Y. 2015-16 was a completed, unabated assessment and that the seized papers were only disclosed returns, audited accounts and ledger entries; no incriminating material was found, so section 153A could not support an addition. On merits, section 41(1) was held inapplicable because the liability write-back did not reverse any prior tax benefit, as the related losses had lapsed without set-off. The assessee's appeal was partly allowed and the Revenue's appeal was dismissed.
Absence of a Document Identification Number in a section 153D approval did not invalidate the assessment, because the curative rule was read to cover assessment proceedings and connected communications, not only the final order. For the search assessment, the Tribunal held that A.Y. 2015-16 was a completed, unabated assessment and that the seized papers were only disclosed returns, audited accounts and ledger entries; no incriminating material was found, so section 153A could not support an addition. On merits, section 41(1) was held inapplicable because the liability write-back did not reverse any prior tax benefit, as the related losses had lapsed without set-off. The assessee's appeal was partly allowed and the Revenue's appeal was dismissed.
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