Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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The ITAT upheld the validity of the reassessment order under section 147 read with section 143(3), finding sufficient new material and reasons to believe that income had escaped assessment for AY 2012-13 based on investigation reports and non-compliance by the assessee. The tribunal rejected the assessee's contention of change of opinion and improper assumption of jurisdiction. However, additions made under section 68 regarding the identity, creditworthiness, and genuineness of share application money were set aside for fresh inquiry, as the AO had not fully verified the parties involved. The AO was directed to conduct further enquiries and provide the assessee with reasonable opportunity of being heard. Additionally, the matter concerning alleged accommodation entries based on the Inspector's report was remanded for reconsideration, with instructions to furnish the report to the assessee and allow them to respond. Grounds relating to these issues were allowed for statistical purposes, while others were dismissed.
The ITAT upheld the validity of the reassessment order under section 147 read with section 143(3), finding sufficient new material and reasons to believe that income had escaped assessment for AY 2012-13 based on investigation reports and non-compliance by the assessee. The tribunal rejected the assessee's contention of change of opinion and improper assumption of jurisdiction. However, additions made under section 68 regarding the identity, creditworthiness, and genuineness of share application money were set aside for fresh inquiry, as the AO had not fully verified the parties involved. The AO was directed to conduct further enquiries and provide the assessee with reasonable opportunity of being heard. Additionally, the matter concerning alleged accommodation entries based on the Inspector's report was remanded for reconsideration, with instructions to furnish the report to the assessee and allow them to respond. Grounds relating to these issues were allowed for statistical purposes, while others were dismissed.
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