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 additions for alleged capital gains and unexplained cash under section 69A, founded solely on uncorroborated personal diary entries and retracted statements of employees/directors, lacked evidentiary foundation and were deleted. Reassessment proceedings initiated by the jurisdictional AO were declared void ab initio as jurisdiction had vested in the Faceless Assessing Officer under the notified scheme; consequently the section 148 notice was coram non judice. The assessment order was also vitiated for failure to generate/quote a valid pre-generated DIN, rendering it a nullity. The appellate enhancement sought by Revenue was held not maintainable for want of cogent material within the scope of matters before the AO/CIT(A).
ITAT held that additions for alleged capital gains and unexplained cash under section 69A, founded solely on uncorroborated personal diary entries and retracted statements of employees/directors, lacked evidentiary foundation and were deleted. Reassessment proceedings initiated by the jurisdictional AO were declared void ab initio as jurisdiction had vested in the Faceless Assessing Officer under the notified scheme; consequently the section 148 notice was coram non judice. The assessment order was also vitiated for failure to generate/quote a valid pre-generated DIN, rendering it a nullity. The appellate enhancement sought by Revenue was held not maintainable for want of cogent material within the scope of matters before the AO/CIT(A).
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