Appeal allows marketing payments as deductible business expenses under Sec.37; director pay retained; R&D deductible from certificate date under Sec.3...
Registration under s.12AB upheld; CIT(Exemptions) exceeded jurisdiction by deciding taxability instead of preliminary verification and registration di...
ITAT allowed the assessee's appeal, quashing reassessment proceedings and consequent additions. The Tribunal held the notice under section 148 issued on 30/07/2022 barred by limitation, the six-year period having expired on 31/03/2022, and reiterated that the earlier 30/06/2021 notice could not be salvaged by TOLA. Independently, the section 148A(b) notice dated 27/05/2022 was held invalid for non-supply of the information/material forming the basis of the reasons, thereby vitiating reopening under section 147. Further, additions under section 69A were not sustained: allegations of VAT evasion and unexplained cash were uncorroborated, speculative and unsupported by any cogent cash-trail or material.
ITAT allowed the assessee's appeal, quashing reassessment proceedings and consequent additions. The Tribunal held the notice under section 148 issued on 30/07/2022 barred by limitation, the six-year period having expired on 31/03/2022, and reiterated that the earlier 30/06/2021 notice could not be salvaged by TOLA. Independently, the section 148A(b) notice dated 27/05/2022 was held invalid for non-supply of the information/material forming the basis of the reasons, thereby vitiating reopening under section 147. Further, additions under section 69A were not sustained: allegations of VAT evasion and unexplained cash were uncorroborated, speculative and unsupported by any cogent cash-trail or material.
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