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ITAT held that proceedings u/s 153A were invalid due to unabated assessment year and absence of incriminating material during search. The Tribunal determined the income received from hospital was professional fees, not salary, thereby entitling the assessee to presumptive taxation under section 44ADA. The AO's arbitrary rejection of 50% income computation was deemed incorrect. CIT(A)'s dismissal without merit-based adjudication was overturned. The assessment order was quashed, and the assessee's appeal was allowed, establishing the professional nature of income and proper tax treatment.
ITAT held that proceedings u/s 153A were invalid due to unabated assessment year and absence of incriminating material during search. The Tribunal determined the income received from hospital was professional fees, not salary, thereby entitling the assessee to presumptive taxation under section 44ADA. The AO's arbitrary rejection of 50% income computation was deemed incorrect. CIT(A)'s dismissal without merit-based adjudication was overturned. The assessment order was quashed, and the assessee's appeal was allowed, establishing the professional nature of income and proper tax treatment.
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