Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
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 
TaxTMI 
of 4894 
