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...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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Validity of assessment u/s 153A regarding unexplained cash credits u/s 68, absence of incriminating material found during search proceedings, and lack of valid approval u/s 153D. The key points are: the assessment proceedings were unabated when the search was conducted; no incriminating material pertaining to the assessment year was found during the search to justify additions u/s 68; statements recorded before or after the search cannot be considered incriminating material; mere observation about investors' financials cannot constitute incriminating material; in the absence of incriminating material, additions cannot be made for unabated assessments; the Assessing Officer continued assessment proceedings and modified the draft order after forwarding it for approval u/s 153D, resulting in material variance from the approved draft order; the final order was passed without valid approval as required u/s 153D, rendering it unsustainable.
Validity of assessment u/s 153A regarding unexplained cash credits u/s 68, absence of incriminating material found during search proceedings, and lack of valid approval u/s 153D. The key points are: the assessment proceedings were unabated when the search was conducted; no incriminating material pertaining to the assessment year was found during the search to justify additions u/s 68; statements recorded before or after the search cannot be considered incriminating material; mere observation about investors' financials cannot constitute incriminating material; in the absence of incriminating material, additions cannot be made for unabated assessments; the Assessing Officer continued assessment proceedings and modified the draft order after forwarding it for approval u/s 153D, resulting in material variance from the approved draft order; the final order was passed without valid approval as required u/s 153D, rendering it unsustainable.
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