Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
The ITAT held that the order passed by the Commissioner of Income Tax (Appeals) [CIT(E)] u/s 263 of the Income Tax Act was quashed. The notice issued u/s 263 was not validly served on the assessee, either through registered post or email, before the hearing date. The notices were served only after the hearing date, violating the principles of natural justice. Additionally, the CIT(E)'s order was passed after the two-year limitation period prescribed u/s 263(2) had expired. Relying on the judgments of M L Chains and Tulsi Tracom (P) Ltd., the ITAT ruled in favor of the assessee, quashing the CIT(E)'s order due to invalid service of notice and the expiry of the limitation period.
The ITAT held that the order passed by the Commissioner of Income Tax (Appeals) [CIT(E)] u/s 263 of the Income Tax Act was quashed. The notice issued u/s 263 was not validly served on the assessee, either through registered post or email, before the hearing date. The notices were served only after the hearing date, violating the principles of natural justice. Additionally, the CIT(E)'s order was passed after the two-year limitation period prescribed u/s 263(2) had expired. Relying on the judgments of M L Chains and Tulsi Tracom (P) Ltd., the ITAT ruled in favor of the assessee, quashing the CIT(E)'s order due to invalid service of notice and the expiry of the limitation period.
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