Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination b...
Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
Service of notice and contractual debt acknowledgment preserved insolvency admission against a corporate guarantor despite limitation and natural just...
ITAT allowed Revenue's appeal, setting aside CIT(A)'s order that had deleted additions made by AO under s.153A. The Tribunal clarified that for assessment years abated as of the search date (02.05.2018), the AO could assess total income based on any material, not just incriminating evidence found during search. CIT(A) had erroneously treated the assessments as unabated. However, ITAT directed deletion of additions related to depreciation on plant/machinery and sub-contract payments, as these were based on third-party statements without allowing cross-examination or providing adequate opportunity for rebuttal to the assessee. The principle that third-party statements require corroborative evidence and opportunity for cross-examination was upheld.
ITAT allowed Revenue's appeal, setting aside CIT(A)'s order that had deleted additions made by AO under s.153A. The Tribunal clarified that for assessment years abated as of the search date (02.05.2018), the AO could assess total income based on any material, not just incriminating evidence found during search. CIT(A) had erroneously treated the assessments as unabated. However, ITAT directed deletion of additions related to depreciation on plant/machinery and sub-contract payments, as these were based on third-party statements without allowing cross-examination or providing adequate opportunity for rebuttal to the assessee. The principle that third-party statements require corroborative evidence and opportunity for cross-examination was upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4830 
Join Channel 
