Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
ITAT ruled in favor of assessee on two key issues. First, the allegation of "on-money" payment for residential property was rejected as the difference between actual payment and registered value cannot be deemed undisclosed income when payments were made through verified banking channels and loan disbursements. Second, DRP's direction to AO for further verification post-DRP proceedings was held ultra vires as per Sec 144C. DRP must conduct verifications during proceedings under 144C(7), not after issuing directions. AO must complete assessment within one month of receiving DRP directions without additional inquiry. Consequently, the addition made in Final Assessment Order was held without jurisdiction and deleted.
ITAT ruled in favor of assessee on two key issues. First, the allegation of "on-money" payment for residential property was rejected as the difference between actual payment and registered value cannot be deemed undisclosed income when payments were made through verified banking channels and loan disbursements. Second, DRP's direction to AO for further verification post-DRP proceedings was held ultra vires as per Sec 144C. DRP must conduct verifications during proceedings under 144C(7), not after issuing directions. AO must complete assessment within one month of receiving DRP directions without additional inquiry. Consequently, the addition made in Final Assessment Order was held without jurisdiction and deleted.
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