Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
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The ITAT Kolkata ruled on the validity of an assessment order u/s 147. The jurisdictional AO did not issue a valid notice u/s 148. The assessee argued that the ACIT lacked jurisdiction and a fresh notice should have been issued by the correct authority. Since no such notice was issued, the assessment proceedings were deemed illegal and void ab initio. The ITAT held that without a valid notice u/s 148, the reassessment proceedings were bad in law and quashed them, deleting the additions made. The appeal by the assessee was allowed.
The ITAT Kolkata ruled on the validity of an assessment order u/s 147. The jurisdictional AO did not issue a valid notice u/s 148. The assessee argued that the ACIT lacked jurisdiction and a fresh notice should have been issued by the correct authority. Since no such notice was issued, the assessment proceedings were deemed illegal and void ab initio. The ITAT held that without a valid notice u/s 148, the reassessment proceedings were bad in law and quashed them, deleting the additions made. The appeal by the assessee was allowed.
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