Belated Form 10B filing during Covid-19 cannot defeat charitable exemption where genuine hardship warrants condonation and substantial justice prevail...
Limitation for consequential assessments runs from prescribed authority receipt, while verified purchases cannot be disallowed merely for unanswered s...
Higher depreciation for qualifying commercial vehicles, exempt-income disallowance, research deduction verification, and club-expense treatment clarif...
Charitable registration renewal cannot become an assessment of receipts, profitability or annual exemption compliance, requiring renewal and donation ...
AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
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Pecuniary jurisdiction over statutory notices under section 143(2) must comply with CBDT instructions allocating cases by returned-income limits. Where an Income-tax Officer issues the notice despite the returned income exceeding that officer's prescribed limit, the defect concerns pecuniary rather than territorial jurisdiction; the territorial-jurisdiction objection rule does not apply. CBDT instructions bind the Department, and issue of a jurisdictional notice by an officer without pecuniary authority is an illegality, not a procedural irregularity capable of validation under section 292BB. The notices and consequential assessment were therefore treated as void from inception and quashed; other grounds remained academic.
Pecuniary jurisdiction over statutory notices under section 143(2) must comply with CBDT instructions allocating cases by returned-income limits. Where an Income-tax Officer issues the notice despite the returned income exceeding that officer's prescribed limit, the defect concerns pecuniary rather than territorial jurisdiction; the territorial-jurisdiction objection rule does not apply. CBDT instructions bind the Department, and issue of a jurisdictional notice by an officer without pecuniary authority is an illegality, not a procedural irregularity capable of validation under section 292BB. The notices and consequential assessment were therefore treated as void from inception and quashed; other grounds remained academic.
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