Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
Reopening of assessment u/s 147 - it is evident that assessing officer has para-wise dealt with the objections of the appellant. We do not feel the need to delve into the issue of sufficiency of reasoning given by the assessing officer while rejecting the objections as the same is of academic nature since we have already upheld the validity of notice u/s 148. - However, AO was not justified in expanding the scope of reassessment proceedings u/s 147 without following the due course and as such the addition is in the teeth of provisions of section 147. - AT
Reopening of assessment u/s 147 - it is evident that assessing officer has para-wise dealt with the objections of the appellant. We do not feel the need to delve into the issue of sufficiency of reasoning given by the assessing officer while rejecting the objections as the same is of academic nature since we have already upheld the validity of notice u/s 148. - However, AO was not justified in expanding the scope of reassessment proceedings u/s 147 without following the due course and as such the addition is in the teeth of provisions of section 147. - AT
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