Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
ITAT allowed the assessee's appeal and quashed the scrutiny assessment. It held that no valid statutory notice u/s 143(2) was issued or served, as the email communication contained no attached, digitally signed notice and was never re-served, rendering the assessment void ab initio. Separately, the approval u/s 153D was found invalid as it was granted through a consolidated, mechanical letter for multiple years, without reference to seized material, appraisal report, or draft orders, and without demonstrating independent application of mind. As approval u/s 153D is a mandatory substantive safeguard, the assessment was held unsustainable in law.
ITAT allowed the assessee's appeal and quashed the scrutiny assessment. It held that no valid statutory notice u/s 143(2) was issued or served, as the email communication contained no attached, digitally signed notice and was never re-served, rendering the assessment void ab initio. Separately, the approval u/s 153D was found invalid as it was granted through a consolidated, mechanical letter for multiple years, without reference to seized material, appraisal report, or draft orders, and without demonstrating independent application of mind. As approval u/s 153D is a mandatory substantive safeguard, the assessment was held unsustainable in law.
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