Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
The ITAT Ahmedabad considered the validity of reassessment proceedings based on borrowed satisfaction by the AO. The AO alleged non-independent application of mind by the assessee in high-value financial transactions leading to unexplained cash credit u/s 68. The AO relied on an investigation report from the Income Tax Department's Investigation Wing. However, the ITAT found that the AO failed to verify double entries in the transactions and did not formulate his own "reason to believe" but relied on information from DGIT, amounting to "borrowed satisfaction." The reassessment was deemed bad in law as the AO did not have an independent reason to believe income had escaped assessment. The decision favored the assessee, following the precedent set in Varshaben Sanatbhai Patgel.
The ITAT Ahmedabad considered the validity of reassessment proceedings based on borrowed satisfaction by the AO. The AO alleged non-independent application of mind by the assessee in high-value financial transactions leading to unexplained cash credit u/s 68. The AO relied on an investigation report from the Income Tax Department's Investigation Wing. However, the ITAT found that the AO failed to verify double entries in the transactions and did not formulate his own "reason to believe" but relied on information from DGIT, amounting to "borrowed satisfaction." The reassessment was deemed bad in law as the AO did not have an independent reason to believe income had escaped assessment. The decision favored the assessee, following the precedent set in Varshaben Sanatbhai Patgel.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
