Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
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The ITAT Ahmedabad held that a best judgment assessment u/s 144 without issuing notice u/s 143(2) is invalid if the assessee has filed a return and responded to AO's notice. Courts emphasize Section 144 is for non-compliance cases. Assessee provided details of cash deposits, supported by affidavits from relatives. Deposits were found to be from maturity proceeds, not unexplained money u/s 69A. Addition in brother's hands linked to joint account. CIT(A) erred in upholding half of assessment u/s 69A. Affidavits, if credible, can explain cash source. Lack of concrete reasons to reject explanations. Entire u/s 69A addition deleted, penalty proceedings u/s 271AAC(1) & 271F dropped. Assessee's appeal allowed.
The ITAT Ahmedabad held that a best judgment assessment u/s 144 without issuing notice u/s 143(2) is invalid if the assessee has filed a return and responded to AO's notice. Courts emphasize Section 144 is for non-compliance cases. Assessee provided details of cash deposits, supported by affidavits from relatives. Deposits were found to be from maturity proceeds, not unexplained money u/s 69A. Addition in brother's hands linked to joint account. CIT(A) erred in upholding half of assessment u/s 69A. Affidavits, if credible, can explain cash source. Lack of concrete reasons to reject explanations. Entire u/s 69A addition deleted, penalty proceedings u/s 271AAC(1) & 271F dropped. Assessee's appeal allowed.
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