Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
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ITAT quashed the assessment order due to procedural non-compliance. The AO improperly initiated reassessment under Section 147 instead of Section 153C when loose papers suggesting a potential Rs.13 Cr payment were discovered during a third-party search. The tribunal found the AO lacked sufficient material evidence to substantiate the undisclosed income claim. Additionally, the absence of a mandatory Section 143(2) notice rendered the assessment unsustainable. Consequently, the tribunal deleted the income addition and accompanying penalty under Section 271D, emphasizing strict adherence to prescribed legal procedures in tax proceedings.
ITAT quashed the assessment order due to procedural non-compliance. The AO improperly initiated reassessment under Section 147 instead of Section 153C when loose papers suggesting a potential Rs.13 Cr payment were discovered during a third-party search. The tribunal found the AO lacked sufficient material evidence to substantiate the undisclosed income claim. Additionally, the absence of a mandatory Section 143(2) notice rendered the assessment unsustainable. Consequently, the tribunal deleted the income addition and accompanying penalty under Section 271D, emphasizing strict adherence to prescribed legal procedures in tax proceedings.
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