Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
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...
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ITAT held that the revision order u/s 263 was invalid. The AO conducted a comprehensive search assessment u/s 153A, thoroughly examining seized materials and assessee's sworn statements. The tribunal found no procedural error or prejudice to revenue's interests, as the assessee had transparently declared and paid taxes on anonymous and corpus donations. The assessment was based on complete verification of facts, and the AO took a plausible view. The tribunal specifically noted that retrospective application of subsequent judicial precedents was impermissible. Consequently, the ITAT quashed the revision order passed by PCIT and allowed the assessee's appeal, affirming the original search assessment order.
ITAT held that the revision order u/s 263 was invalid. The AO conducted a comprehensive search assessment u/s 153A, thoroughly examining seized materials and assessee's sworn statements. The tribunal found no procedural error or prejudice to revenue's interests, as the assessee had transparently declared and paid taxes on anonymous and corpus donations. The assessment was based on complete verification of facts, and the AO took a plausible view. The tribunal specifically noted that retrospective application of subsequent judicial precedents was impermissible. Consequently, the ITAT quashed the revision order passed by PCIT and allowed the assessee's appeal, affirming the original search assessment order.
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