Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
ITAT held that assessment framed u/s 153C for AY 2011-12 is barred by limitation and vitiated due to lack of valid 'satisfaction note', rendering entire proceedings under s. 153C a non-starter. For AYs 2012-13 to 2015-16, ITAT found legal infirmities in 'satisfaction note' lacking objectivity, vitiating assumption of jurisdiction u/s 153C. Resultant assessment orders passed u/s 153C for these AYs were quashed being non-est.
ITAT held that assessment framed u/s 153C for AY 2011-12 is barred by limitation and vitiated due to lack of valid 'satisfaction note', rendering entire proceedings under s. 153C a non-starter. For AYs 2012-13 to 2015-16, ITAT found legal infirmities in 'satisfaction note' lacking objectivity, vitiating assumption of jurisdiction u/s 153C. Resultant assessment orders passed u/s 153C for these AYs were quashed being non-est.
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