Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
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HC held that the CIT(A)'s order directing deletion of additions relating to unexplained sundry creditors was valid. The AO's amendment under Section 154 was procedurally flawed as no notice was issued to the assessee, violating statutory requirements of Section 154(3). The court found a clear violation of natural justice principles by not providing an opportunity of hearing. Consequently, the order dated February 7, 2025 was set aside, and the authorities were directed to implement the previous order dated January 3, 2024 within four weeks, effectively reinstating the original appellate order deleting the contested additions.
HC held that the CIT(A)'s order directing deletion of additions relating to unexplained sundry creditors was valid. The AO's amendment under Section 154 was procedurally flawed as no notice was issued to the assessee, violating statutory requirements of Section 154(3). The court found a clear violation of natural justice principles by not providing an opportunity of hearing. Consequently, the order dated February 7, 2025 was set aside, and the authorities were directed to implement the previous order dated January 3, 2024 within four weeks, effectively reinstating the original appellate order deleting the contested additions.
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