Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
Reopening of assessment u/s 147 - As the reopening in the case before us had been resorted to by the A.O on the basis of a “change of opinion” as regards the allowability of deduction of the sales promotion expenses, on the same set of facts and material as were there before his predecessor who had framed the regular assessment vide his order passed under Sec. 143(3), order quashed for want of jurisdiction. - AT
Reopening of assessment u/s 147 - As the reopening in the case before us had been resorted to by the A.O on the basis of a “change of opinion” as regards the allowability of deduction of the sales promotion expenses, on the same set of facts and material as were there before his predecessor who had framed the regular assessment vide his order passed under Sec. 143(3), order quashed for want of jurisdiction. - AT
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