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 crux of the matter revolves around the reopening of assessment u/s 147 of the Act and the addition made u/s 68 treating the share application received as a non-genuine transaction and accommodation entry. The key points are: The reopening was initiated based on the incriminating material found during a search operation at the premises of a third party, indicating that the assessee had obtained an entry from an entry operator. The Assessing Officer heavily relied on the report of the Investigation Wing without independently verifying the facts. The assessee contended that the reopening u/s 147 was unjustified as the incriminating material was recovered during a search, and the proper course should have been proceedings u/s 153C. The ITAT held that the Assessing Officer was not justified in reopening the assessment u/s 147 when the incriminating material was found during a search at a third party's premises. The CIT(A) failed to address the specific grounds raised by the assessee regarding the legality of reopening the assessment.
The crux of the matter revolves around the reopening of assessment u/s 147 of the Act and the addition made u/s 68 treating the share application received as a non-genuine transaction and accommodation entry. The key points are: The reopening was initiated based on the incriminating material found during a search operation at the premises of a third party, indicating that the assessee had obtained an entry from an entry operator. The Assessing Officer heavily relied on the report of the Investigation Wing without independently verifying the facts. The assessee contended that the reopening u/s 147 was unjustified as the incriminating material was recovered during a search, and the proper course should have been proceedings u/s 153C. The ITAT held that the Assessing Officer was not justified in reopening the assessment u/s 147 when the incriminating material was found during a search at a third party's premises. The CIT(A) failed to address the specific grounds raised by the assessee regarding the legality of reopening the assessment.
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