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...
The case involved the scope of limited scrutiny and the validity of a notice u/s 143(2) of the Income Tax Act. The assessee's case was selected for limited scrutiny to verify cash deposits during demonetization. However, the Assessing Officer (AO) attempted to convert the limited scrutiny into a full scrutiny. The Tribunal held that although the notice mentioned limited scrutiny, the subsequent paragraphs referred to scrutiny without specifying its limited nature. The AO identified the issue for examination as cash deposits during demonetization, indicating a limited purpose. To enlarge the scope and make other additions, the AO should have followed the procedure laid down by the CBDT's Instruction No. 5. Since the AO did not make any addition regarding cash deposits during demonetization and the assessee had deposited small accepted amounts, the assessment order was quashed for exceeding the AO's limited powers. The appeal was allowed, and the Tribunal emphasized the need to follow due procedure for converting a limited scrutiny into a full scrutiny.
The case involved the scope of limited scrutiny and the validity of a notice u/s 143(2) of the Income Tax Act. The assessee's case was selected for limited scrutiny to verify cash deposits during demonetization. However, the Assessing Officer (AO) attempted to convert the limited scrutiny into a full scrutiny. The Tribunal held that although the notice mentioned limited scrutiny, the subsequent paragraphs referred to scrutiny without specifying its limited nature. The AO identified the issue for examination as cash deposits during demonetization, indicating a limited purpose. To enlarge the scope and make other additions, the AO should have followed the procedure laid down by the CBDT's Instruction No. 5. Since the AO did not make any addition regarding cash deposits during demonetization and the assessee had deposited small accepted amounts, the assessment order was quashed for exceeding the AO's limited powers. The appeal was allowed, and the Tribunal emphasized the need to follow due procedure for converting a limited scrutiny into a full scrutiny.
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