Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Reassessment notices issued u/s 148 for assessment years 2018-19, 2019-20, and 2020-21 were time-barred by limitation. Withdrawal of approval u/s 10(23C)(vi) by the Principal Commissioner of Income Tax (PCIT) was invalid as there were no valid pending proceedings before the Assessing Officer. The second proviso to section 143(3), allowing the Assessing Officer to make a reference, was applicable only from assessment year 2022-23 onwards. The PCIT lacked jurisdiction, as the Commissioner (Exemption) with territorial jurisdiction should have approved or withdrawn the approval. The Appellate Tribunal decided in favor of the assessee, quashing the PCIT's orders withdrawing approval u/s 10(23C)(vi) due to lack of jurisdiction and invalid reassessment proceedings.
Reassessment notices issued u/s 148 for assessment years 2018-19, 2019-20, and 2020-21 were time-barred by limitation. Withdrawal of approval u/s 10(23C)(vi) by the Principal Commissioner of Income Tax (PCIT) was invalid as there were no valid pending proceedings before the Assessing Officer. The second proviso to section 143(3), allowing the Assessing Officer to make a reference, was applicable only from assessment year 2022-23 onwards. The PCIT lacked jurisdiction, as the Commissioner (Exemption) with territorial jurisdiction should have approved or withdrawn the approval. The Appellate Tribunal decided in favor of the assessee, quashing the PCIT's orders withdrawing approval u/s 10(23C)(vi) due to lack of jurisdiction and invalid reassessment proceedings.
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