Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
Validity of reopening of assessment - doctrine of merger - The ITAT unequivocally quashed the reassessment proceedings initiated against the appellant for the Assessment Year 2006-07, ruling them as bad-in-law due to the procedural flaw of issuing a notice under section 147 beyond the four-year period without specifying the particulars of omitted income - The judgment also indirectly supports the appellant's contention regarding the classification of certain incomes as business incomes eligible for section 80IA deductions, though this specific issue became moot following the quashing of the reassessment order.
Validity of reopening of assessment - doctrine of merger - The ITAT unequivocally quashed the reassessment proceedings initiated against the appellant for the Assessment Year 2006-07, ruling them as bad-in-law due to the procedural flaw of issuing a notice under section 147 beyond the four-year period without specifying the particulars of omitted income - The judgment also indirectly supports the appellant's contention regarding the classification of certain incomes as business incomes eligible for section 80IA deductions, though this specific issue became moot following the quashing of the reassessment order.
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