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Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
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Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
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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