Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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ITAT held that a PCIT order under s.127 effected exclusive jurisdiction transfer to DCIT/ACIT, Central Circle-2, Madurai with effect from 09.12.2020; administrative delay in ITBA migration does not defer legal effect. Consequently, the ITO, Ward-4, Tirunelveli's notice issued u/s 143(2) on 29.06.2021 was without jurisdiction, invalid and liable to be quashed, rendering any resulting assessment order void ab initio. On merits, ITAT upheld the CIT(A)'s deletion of additions: an addition for alleged undisclosed business income based solely on survey notings was unsupported by corroborative evidence, and an addition u/s 68 read with s.115BBE was incorrect as amounts were opening balances, not credits in the year.
ITAT held that a PCIT order under s.127 effected exclusive jurisdiction transfer to DCIT/ACIT, Central Circle-2, Madurai with effect from 09.12.2020; administrative delay in ITBA migration does not defer legal effect. Consequently, the ITO, Ward-4, Tirunelveli's notice issued u/s 143(2) on 29.06.2021 was without jurisdiction, invalid and liable to be quashed, rendering any resulting assessment order void ab initio. On merits, ITAT upheld the CIT(A)'s deletion of additions: an addition for alleged undisclosed business income based solely on survey notings was unsupported by corroborative evidence, and an addition u/s 68 read with s.115BBE was incorrect as amounts were opening balances, not credits in the year.
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