Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
ITAT held that the assessments framed u/s 153C read with 153D are invalid for lack of jurisdiction: the deemed date of search was 17.10.2022 so s.153C could not be invoked, the requisite satisfaction note was neither supplied nor properly recorded (a consolidated note for multiple years vitiated proceedings), and sanction u/s 153D was mechanical and without application of mind. Consequential additions were set aside: alleged capital gains based solely on seizure spreadsheets without corroboration were not sustained, the s.54B relief already allowed in earlier s.143(3) proceedings was not revisit-able under s.153C, and reopening under s.148 amounted to change of opinion and was therefore invalid. Appeals allowed in favour of the assessee.
ITAT held that the assessments framed u/s 153C read with 153D are invalid for lack of jurisdiction: the deemed date of search was 17.10.2022 so s.153C could not be invoked, the requisite satisfaction note was neither supplied nor properly recorded (a consolidated note for multiple years vitiated proceedings), and sanction u/s 153D was mechanical and without application of mind. Consequential additions were set aside: alleged capital gains based solely on seizure spreadsheets without corroboration were not sustained, the s.54B relief already allowed in earlier s.143(3) proceedings was not revisit-able under s.153C, and reopening under s.148 amounted to change of opinion and was therefore invalid. Appeals allowed in favour of the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4794
Join Channel
TaxTMI 
