Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
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Regarding the additions made u/s 153A, the ITAT held that since no incriminating material was referred to by the Assessing Officer (AO) during the search, no additions could be made in a completed assessment as per the Supreme Court's decision in Abhisar Buildwell Pvt. Ltd. Secondly, concerning the addition of bogus purchases, the ITAT observed that the purchases were accounted for in the regular books, and the source of payments was duly explained. Hence, the provisions of Section 69C were not applicable. Thirdly, regarding the addition u/s 69A, the ITAT upheld the Commissioner of Income Tax (Appeals) [CIT(A)]'s deletion of the addition, considering the assessee's retracted undisclosed income figure backed by credible evidence and the presumption u/ss 132(4A) and 292C.
Regarding the additions made u/s 153A, the ITAT held that since no incriminating material was referred to by the Assessing Officer (AO) during the search, no additions could be made in a completed assessment as per the Supreme Court's decision in Abhisar Buildwell Pvt. Ltd. Secondly, concerning the addition of bogus purchases, the ITAT observed that the purchases were accounted for in the regular books, and the source of payments was duly explained. Hence, the provisions of Section 69C were not applicable. Thirdly, regarding the addition u/s 69A, the ITAT upheld the Commissioner of Income Tax (Appeals) [CIT(A)]'s deletion of the addition, considering the assessee's retracted undisclosed income figure backed by credible evidence and the presumption u/ss 132(4A) and 292C.
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