Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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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