Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
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...
The ITAT held that the AO lacked jurisdiction to reopen assessments for AYs 2012-13 and 2013-14 under section 153C, as no incriminating material was found during the search that could substantiate additions. The tribunal quashed the reassessment orders, finding the jurisdictional fact absent and following the Supreme Court's precedent in DCIT vs U.K. Paints. The statement from a third party was deemed insufficient to draw adverse inferences, and the tribunal directed deletion of additions made under section 69. Consequently, the assessee's appeals were allowed, invalidating the impugned assessment orders.
The ITAT held that the AO lacked jurisdiction to reopen assessments for AYs 2012-13 and 2013-14 under section 153C, as no incriminating material was found during the search that could substantiate additions. The tribunal quashed the reassessment orders, finding the jurisdictional fact absent and following the Supreme Court's precedent in DCIT vs U.K. Paints. The statement from a third party was deemed insufficient to draw adverse inferences, and the tribunal directed deletion of additions made under section 69. Consequently, the assessee's appeals were allowed, invalidating the impugned assessment orders.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
