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 appeals and quashed the assessments framed u/s 153A r.w.s. 144/143(3) for AYs 2013-14 and 2014-15. It held that the assessments were invalid due to lack of a legally sustainable approval u/s 153D, granted mechanically and without application of mind, and were vitiated by serious violation of principles of natural justice, including denial of effective opportunity and completion of assessment within two days of return filing. For AY 2014-15, the assessment was additionally held bad in law for non-issuance of notice u/s 143(2) after transfer of jurisdiction. Additions were not examined on merits.
ITAT allowed the assessee's appeals and quashed the assessments framed u/s 153A r.w.s. 144/143(3) for AYs 2013-14 and 2014-15. It held that the assessments were invalid due to lack of a legally sustainable approval u/s 153D, granted mechanically and without application of mind, and were vitiated by serious violation of principles of natural justice, including denial of effective opportunity and completion of assessment within two days of return filing. For AY 2014-15, the assessment was additionally held bad in law for non-issuance of notice u/s 143(2) after transfer of jurisdiction. Additions were not examined on merits.
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