Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Development rights transfers treated as immovable property, while construction abatement applies and repeated non-payment permits extended service-tax...
Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
Assessment order u/s 143(3) passed against an individual beneficiary, determining the primary assessee liable for taxation. The key points are: the assessment order was passed against the individual beneficiary, not the trust. Although the trust is the primary assessee u/s 160(1)(iv), the department can directly assess the beneficiary u/s 166. Since the assessment was framed against the beneficiary, the beneficiary should have filed an appeal before the CIT(Appeals), not the trust. The trust's appeal is dismissed, and the beneficiary is allowed to file a delayed appeal before the CIT(Appeals), who is directed to adopt a liberal approach regarding the delay. The issue pertains to the determination of the primary assessee liable for taxation and the unexplained cash deposits u/s 69A, where no source was provided.
Assessment order u/s 143(3) passed against an individual beneficiary, determining the primary assessee liable for taxation. The key points are: the assessment order was passed against the individual beneficiary, not the trust. Although the trust is the primary assessee u/s 160(1)(iv), the department can directly assess the beneficiary u/s 166. Since the assessment was framed against the beneficiary, the beneficiary should have filed an appeal before the CIT(Appeals), not the trust. The trust's appeal is dismissed, and the beneficiary is allowed to file a delayed appeal before the CIT(Appeals), who is directed to adopt a liberal approach regarding the delay. The issue pertains to the determination of the primary assessee liable for taxation and the unexplained cash deposits u/s 69A, where no source was provided.
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