Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
The court held that the notices issued u/s 133(6) and the subsequent notice u/s 148 of the Income Tax Act were invalid. The petitioner had filed a reply to the notice u/s 133(6), but it was erroneously stated that no reply was received. The court found that the amount in question was already included in the petitioner's income tax return and duly processed by the Assessing Officer. The court concluded that the notice u/s 148 was issued without proper application of mind and was vitiated. Additionally, the court held that the officer who issued the notices lacked competence, as per the judgment in Jasjit Singh case, which ruled that notices issued by the Joint Assessing Officer u/s 148 without conducting faceless assessment u/s 144B were contrary to the provisions of the Act. Consequently, the court quashed the impugned notices issued u/ss 133(6) and 148.
The court held that the notices issued u/s 133(6) and the subsequent notice u/s 148 of the Income Tax Act were invalid. The petitioner had filed a reply to the notice u/s 133(6), but it was erroneously stated that no reply was received. The court found that the amount in question was already included in the petitioner's income tax return and duly processed by the Assessing Officer. The court concluded that the notice u/s 148 was issued without proper application of mind and was vitiated. Additionally, the court held that the officer who issued the notices lacked competence, as per the judgment in Jasjit Singh case, which ruled that notices issued by the Joint Assessing Officer u/s 148 without conducting faceless assessment u/s 144B were contrary to the provisions of the Act. Consequently, the court quashed the impugned notices issued u/ss 133(6) and 148.
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