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...
Reassessment cannot be sustained for an unrelated income item where the income forming the recorded reasons is accepted and no addition is made on that basis. The notes explain that an Assessing Officer who initiated reassessment to examine share application money could not independently add an unsecured loan identified through separate information without issuing a fresh notice under section 148. Applying the principle in Jet Airways and a subsequent ITAT decision, the reassessment addition was treated as outside the permissible scope of reassessment. The assessee succeeded on this legal issue, and the merits of the unsecured-loan addition and other grounds were not examined.
Reassessment cannot be sustained for an unrelated income item where the income forming the recorded reasons is accepted and no addition is made on that basis. The notes explain that an Assessing Officer who initiated reassessment to examine share application money could not independently add an unsecured loan identified through separate information without issuing a fresh notice under section 148. Applying the principle in Jet Airways and a subsequent ITAT decision, the reassessment addition was treated as outside the permissible scope of reassessment. The assessee succeeded on this legal issue, and the merits of the unsecured-loan addition and other grounds were not examined.
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