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Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
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Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The Income Tax Appellate Tribunal held that the assessment order u/s 153A for the assessment year 2008-09 was invalid as it was beyond the period of limitation of ten years from the end of the relevant assessment year in which the search was conducted. The Tribunal observed that no incriminating material was found during the search, and initiating proceedings barred by law cannot be allowed. Furthermore, the Commissioner of Income Tax (Appeals) rightly deleted the addition made by the Assessing Officer on the grounds that the assessee was not involved in the wool business. The CIT(A) verified the documentary evidence and acknowledged that the investment in mutual funds was duly recorded in the audited financial statements and tax audit report. The Tribunal affirmed the CIT(A)'s findings that the assessee's business activity and operations were genuine for the year under consideration.
The Income Tax Appellate Tribunal held that the assessment order u/s 153A for the assessment year 2008-09 was invalid as it was beyond the period of limitation of ten years from the end of the relevant assessment year in which the search was conducted. The Tribunal observed that no incriminating material was found during the search, and initiating proceedings barred by law cannot be allowed. Furthermore, the Commissioner of Income Tax (Appeals) rightly deleted the addition made by the Assessing Officer on the grounds that the assessee was not involved in the wool business. The CIT(A) verified the documentary evidence and acknowledged that the investment in mutual funds was duly recorded in the audited financial statements and tax audit report. The Tribunal affirmed the CIT(A)'s findings that the assessee's business activity and operations were genuine for the year under consideration.
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