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...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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Assessments u/s 153A for AYs 2012-13, 2013-14 & 2014-15 were made based on statement of third party and material from search of third party, without any incriminating material found in assessee's case. As per SC ruling in Pr. CIT v. Abhisar Buildwell, such additions are impermissible u/s 153A. For abated AYs 2015-16 onwards, AO's powers aren't limited to incriminating material from search. However, where AO accepted assessee's explanation on source of funds based on documentary evidence in remand report, CIT(A) erred in brushing it aside without substantive reasons. Additions sustained by CIT(A) despite AO's findings in remand report are unsustainable.
Assessments u/s 153A for AYs 2012-13, 2013-14 & 2014-15 were made based on statement of third party and material from search of third party, without any incriminating material found in assessee's case. As per SC ruling in Pr. CIT v. Abhisar Buildwell, such additions are impermissible u/s 153A. For abated AYs 2015-16 onwards, AO's powers aren't limited to incriminating material from search. However, where AO accepted assessee's explanation on source of funds based on documentary evidence in remand report, CIT(A) erred in brushing it aside without substantive reasons. Additions sustained by CIT(A) despite AO's findings in remand report are unsustainable.
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