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ITAT holds that approvals under s.153D were granted mechanically...
Approvals under s.153D found mechanical and invalid; s.153A/s.153D assessments quashed; s.68 additions deleted where books rejected and s.144 best-judgment applied
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ITAT holds that approvals under s.153D were granted mechanically and, being invalid, vitiate assessment orders framed under s.153A read with s.153D for AYs 2014-15 to 2019-20, which are quashed. Tribunal rules that additions under s.68 cannot be made for opening balances or notional book entries representing earlier years; such amounts and alleged unsecured loans shown as carried-forward balances are not exigible in the year under assessment and are deleted. Where books were rejected u/s 145(3) and best-judgment estimation u/s 144 was applied, no separate s.68 addition could be sustained. Alleged inter-unit profits cannot be recharacterized to avoid double taxation absent corroborative evidence.
ITAT holds that approvals under s.153D were granted mechanically and, being invalid, vitiate assessment orders framed under s.153A read with s.153D for AYs 2014-15 to 2019-20, which are quashed. Tribunal rules that additions under s.68 cannot be made for opening balances or notional book entries representing earlier years; such amounts and alleged unsecured loans shown as carried-forward balances are not exigible in the year under assessment and are deleted. Where books were rejected u/s 145(3) and best-judgment estimation u/s 144 was applied, no separate s.68 addition could be sustained. Alleged inter-unit profits cannot be recharacterized to avoid double taxation absent corroborative evidence.
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