Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
The ITAT held that the absence of commencement of search pursuant to a warrant of authorization under section 132 at the registered office or any specified premises precludes the invocation of section 153A. Mere issuance or mention of the assessee's name on the warrant is insufficient without actual execution of the search and seizure process. Section 292B, which addresses procedural defects, cannot be employed to extend the scope of section 153A to cases where no search has been conducted. Furthermore, section 292BB pertains solely to the validity of notice service and does not confer jurisdiction where it does not otherwise exist. Consequently, the Tribunal upheld the CIT(A)'s decision dismissing the revenue's appeal, affirming that the reassessment proceedings under section 153A were invalid in the absence of a valid search operation.
The ITAT held that the absence of commencement of search pursuant to a warrant of authorization under section 132 at the registered office or any specified premises precludes the invocation of section 153A. Mere issuance or mention of the assessee's name on the warrant is insufficient without actual execution of the search and seizure process. Section 292B, which addresses procedural defects, cannot be employed to extend the scope of section 153A to cases where no search has been conducted. Furthermore, section 292BB pertains solely to the validity of notice service and does not confer jurisdiction where it does not otherwise exist. Consequently, the Tribunal upheld the CIT(A)'s decision dismissing the revenue's appeal, affirming that the reassessment proceedings under section 153A were invalid in the absence of a valid search operation.
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