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...
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.
Note: It is a system-generated summary and is for quick reference only.