Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
The ITAT allowed the assessee's appeal, holding that the assumption of jurisdiction u/s 153C of the Income Tax Act by the Assessing Officer was vitiated due to a lack of proper 'satisfaction note'. The 'satisfaction note' lacked tangible and descriptive information, indicating a lack of application of mind. Consequently, the notice issued u/s 153C and the consequent assessment order were quashed. Additionally, regarding the valuation of a property, the ITAT accepted the assessee's contention and the District Valuation Officer's report, which was closer to the declared sale consideration. The significant difference between the sale consideration mentioned in the Agreement to Sale and the Sale Deed was deemed unconceivable and contrary to the estimated market value. The assessee's declared sale consideration was upheld in the absence of any contrary inquiry by the Revenue.
The ITAT allowed the assessee's appeal, holding that the assumption of jurisdiction u/s 153C of the Income Tax Act by the Assessing Officer was vitiated due to a lack of proper 'satisfaction note'. The 'satisfaction note' lacked tangible and descriptive information, indicating a lack of application of mind. Consequently, the notice issued u/s 153C and the consequent assessment order were quashed. Additionally, regarding the valuation of a property, the ITAT accepted the assessee's contention and the District Valuation Officer's report, which was closer to the declared sale consideration. The significant difference between the sale consideration mentioned in the Agreement to Sale and the Sale Deed was deemed unconceivable and contrary to the estimated market value. The assessee's declared sale consideration was upheld in the absence of any contrary inquiry by the Revenue.
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