Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
ITAT ruled the assessment order invalid due to procedural deficiencies and lack of proper jurisdiction. The AO failed to issue mandatory notice under Section 143(2) before assessment, which the SC has established as sine qua non for jurisdictional validity. The assessment order was deemed cryptic, lacking detailed analysis of transactions, correlation with books of accounts, and source identification for alleged unexplained cash credits. The AO also failed to address the assessee's objections regarding reopening of assessment. Despite similar grounds for reopening assessment in AY 2012-13, no additions were made for that year. The tribunal quashed the reopening as legally defective and found the additions unsustainable on merits. Appeal allowed in favor of assessee.
ITAT ruled the assessment order invalid due to procedural deficiencies and lack of proper jurisdiction. The AO failed to issue mandatory notice under Section 143(2) before assessment, which the SC has established as sine qua non for jurisdictional validity. The assessment order was deemed cryptic, lacking detailed analysis of transactions, correlation with books of accounts, and source identification for alleged unexplained cash credits. The AO also failed to address the assessee's objections regarding reopening of assessment. Despite similar grounds for reopening assessment in AY 2012-13, no additions were made for that year. The tribunal quashed the reopening as legally defective and found the additions unsustainable on merits. Appeal allowed in favor of assessee.
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