Belated Form 10B filing during Covid-19 cannot defeat charitable exemption where genuine hardship warrants condonation and substantial justice prevail...
Limitation for consequential assessments runs from prescribed authority receipt, while verified purchases cannot be disallowed merely for unanswered s...
Higher depreciation for qualifying commercial vehicles, exempt-income disallowance, research deduction verification, and club-expense treatment clarif...
Charitable registration renewal cannot become an assessment of receipts, profitability or annual exemption compliance, requiring renewal and donation ...
AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
Reopening of assessment u/s 147 - Reasons to believe - The ITAT thoroughly examined the reasons recorded by the AO for re-opening the assessment and found that there was no new or tangible material available to justify the re-opening. It was established that the AO had already examined and allowed the assessee's claim of deduction under Section 80IB(10) during the original assessment proceedings after due application of mind. The Tribunal concluded that the re-opening of the assessment was solely based on a re-appraisal of the same material available during the original assessment, amounting to a review of the decision taken earlier, which is legally impermissible.
Reopening of assessment u/s 147 - Reasons to believe - The ITAT thoroughly examined the reasons recorded by the AO for re-opening the assessment and found that there was no new or tangible material available to justify the re-opening. It was established that the AO had already examined and allowed the assessee's claim of deduction under Section 80IB(10) during the original assessment proceedings after due application of mind. The Tribunal concluded that the re-opening of the assessment was solely based on a re-appraisal of the same material available during the original assessment, amounting to a review of the decision taken earlier, which is legally impermissible.
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