Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
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...
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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