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...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Validity of reopening an assessment beyond four years from the end of the relevant assessment year, denial of deduction u/s 54F, and the addition on the ground of owning more than one residential house. The key points are: the assessee did not fail to furnish requisite details, satisfying the proviso to Section 147; the Assessing Officer could not have validly assumed jurisdiction u/s 147 based on website information; different floors of a property cannot be construed as independent residential units, as decided by the Tribunal in the assessee's own wealth tax case; merely having several independent residential units does not impact the claim for deduction u/s 54F. The reassessment proceedings were quashed, and the assessee was entitled to a deduction of Rs. 90 crores u/s 54F. The denial of deduction u/s 54F for not utilizing the entire sale proceeds was addressed, clarifying that no deduction u/s 80G was claimed for the donation to the trust. The loan from Alert Buildtech was accepted as genuine, and no addition was made u/s 68.
Validity of reopening an assessment beyond four years from the end of the relevant assessment year, denial of deduction u/s 54F, and the addition on the ground of owning more than one residential house. The key points are: the assessee did not fail to furnish requisite details, satisfying the proviso to Section 147; the Assessing Officer could not have validly assumed jurisdiction u/s 147 based on website information; different floors of a property cannot be construed as independent residential units, as decided by the Tribunal in the assessee's own wealth tax case; merely having several independent residential units does not impact the claim for deduction u/s 54F. The reassessment proceedings were quashed, and the assessee was entitled to a deduction of Rs. 90 crores u/s 54F. The denial of deduction u/s 54F for not utilizing the entire sale proceeds was addressed, clarifying that no deduction u/s 80G was claimed for the donation to the trust. The loan from Alert Buildtech was accepted as genuine, and no addition was made u/s 68.
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