Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
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...
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Reopening of assessment u/s 147 - validity of notice u/s 148A - alleged income which is said to have escaped assessment is much below Rs. 50,00,000 - Only on the basis that the cash deposits chargeable to tax have escaped assessment, without anything more, the authority was not justified in jumping to the conclusion that the assessee may have more bank accounts. If such an interpretation is placed on the provision of Section 148A (d) of the Act with reference to expression ‘material available on record’, then in that case, it will open flood gate and even without availability of any material, the authority would be initiating proceedings u/s 148 of the Act, which will completely frustrate the object of incorporation of Section 148A in the Act. - HC
Reopening of assessment u/s 147 - validity of notice u/s 148A - alleged income which is said to have escaped assessment is much below Rs. 50,00,000 - Only on the basis that the cash deposits chargeable to tax have escaped assessment, without anything more, the authority was not justified in jumping to the conclusion that the assessee may have more bank accounts. If such an interpretation is placed on the provision of Section 148A (d) of the Act with reference to expression ‘material available on record’, then in that case, it will open flood gate and even without availability of any material, the authority would be initiating proceedings u/s 148 of the Act, which will completely frustrate the object of incorporation of Section 148A in the Act. - HC
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