Appeal dismissed: petitioner denied ITC for electricity used in township maintenance as residential supply; Explanation 1(d) prospective under s.2(17)...
Registration under section 12AA granted where substantive charitable objects for ex-servicemen, incidental commercial activity permitted and profits a...
ITAT upheld the CIT(A)'s deletion of additions, holding that the satisfaction note did not identify any incriminating material seized that disclosed undisclosed income under s.153C; the transaction (sale consideration of Rs.10.43 crore) was already declared in the assesee's returns for AY 2012-13 and AY 2014-15 and assessed. The Tribunal found seized documents (including ikrarnamas and registered deed) related to the same disclosed transaction and were not shown to generate new incriminating information; revenue failed to demonstrate that seized material disclosed undisclosed income. Consequently, jurisdictional prerequisites for invoking s.153A read with s.153C were not satisfied, and the CIT(A) order deleting the addition was affirmed.
ITAT upheld the CIT(A)'s deletion of additions, holding that the satisfaction note did not identify any incriminating material seized that disclosed undisclosed income under s.153C; the transaction (sale consideration of Rs.10.43 crore) was already declared in the assesee's returns for AY 2012-13 and AY 2014-15 and assessed. The Tribunal found seized documents (including ikrarnamas and registered deed) related to the same disclosed transaction and were not shown to generate new incriminating information; revenue failed to demonstrate that seized material disclosed undisclosed income. Consequently, jurisdictional prerequisites for invoking s.153A read with s.153C were not satisfied, and the CIT(A) order deleting the addition was affirmed.
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