Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
HC quashed reassessment proceedings under s.147 initiated after four years. AO's reasons revealed information was derived from original assessment documents, indicating predecessor officer's incorrect assessment. Court found jurisdictional conditions under first proviso to s.147 unsatisfied. AO failed to adequately address petitioner's jurisdictional objections in rejection order, merely citing judgments without specific rebuttals. Though respondents later cited audit objections, these were not mentioned in original reasons or objection order. Court held reassessment notice under s.148 was without jurisdiction, illegal and arbitrary, as reopening must be tested solely on recorded reasons without subsequent additions.
HC quashed reassessment proceedings under s.147 initiated after four years. AO's reasons revealed information was derived from original assessment documents, indicating predecessor officer's incorrect assessment. Court found jurisdictional conditions under first proviso to s.147 unsatisfied. AO failed to adequately address petitioner's jurisdictional objections in rejection order, merely citing judgments without specific rebuttals. Though respondents later cited audit objections, these were not mentioned in original reasons or objection order. Court held reassessment notice under s.148 was without jurisdiction, illegal and arbitrary, as reopening must be tested solely on recorded reasons without subsequent additions.
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