Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
The case involves the reopening of assessment u/s 147 to determine if the assessee is a non-filer. Reopening was based on a survey operation at a hotel owned by the wife of the HUF's Karta. The assessee's original return filing status was not mentioned in the reasons recorded by the AO, leading to an invalid assumption of jurisdiction u/s 148. Citing relevant case law, including Gaurav Joshi, 'Sagar Enterprises', 'Fortune Metaliks Ltd.', 'Monika Rani', and 'Baba Kartar Singh Dukku Education Trust', the Tribunal held that incorrect facts regarding return filing render the jurisdiction u/s 148 invalid due to lack of independent assessment by the AO. Decision favors the assessee.
The case involves the reopening of assessment u/s 147 to determine if the assessee is a non-filer. Reopening was based on a survey operation at a hotel owned by the wife of the HUF's Karta. The assessee's original return filing status was not mentioned in the reasons recorded by the AO, leading to an invalid assumption of jurisdiction u/s 148. Citing relevant case law, including Gaurav Joshi, 'Sagar Enterprises', 'Fortune Metaliks Ltd.', 'Monika Rani', and 'Baba Kartar Singh Dukku Education Trust', the Tribunal held that incorrect facts regarding return filing render the jurisdiction u/s 148 invalid due to lack of independent assessment by the AO. Decision favors the assessee.
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