Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
Validity of order u/s 92CA (3) on the ground of limitation as contemplated u/s 153 - As the order of the Ld. TPO is barred by limitation, there is no variation to the income of the assessee pursuance to the reference made the Ld. TPO. Accordingly, assessee does not qualify to be an eligible assessee u/s 144C(15)(b). Thus, the moment the order of the TPO is quashed the assessee ceases to be an ‘eligible assessee’. Therefore, in that circumstances the time limit for completion of the assessment reverts back to 21 months. - AT
Validity of order u/s 92CA (3) on the ground of limitation as contemplated u/s 153 - As the order of the Ld. TPO is barred by limitation, there is no variation to the income of the assessee pursuance to the reference made the Ld. TPO. Accordingly, assessee does not qualify to be an eligible assessee u/s 144C(15)(b). Thus, the moment the order of the TPO is quashed the assessee ceases to be an ‘eligible assessee’. Therefore, in that circumstances the time limit for completion of the assessment reverts back to 21 months. - AT
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