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 held the notice issued u/s 143(2) invalid as it mentioned only "computer aided scrutiny selection" without specifying whether the case was under limited, complete, or compulsory manual scrutiny, contrary to binding CBDT instructions. Non-compliance with such instructions vitiated the jurisdiction assumed by the AO. Consequently, the assessment framed pursuant to the defective notice was declared void and quashed in entirety. The Tribunal followed its earlier coordinate bench ruling in a similar fact situation, and allowed the assessee's appeal, annulling the impugned assessment proceedings.
ITAT held the notice issued u/s 143(2) invalid as it mentioned only "computer aided scrutiny selection" without specifying whether the case was under limited, complete, or compulsory manual scrutiny, contrary to binding CBDT instructions. Non-compliance with such instructions vitiated the jurisdiction assumed by the AO. Consequently, the assessment framed pursuant to the defective notice was declared void and quashed in entirety. The Tribunal followed its earlier coordinate bench ruling in a similar fact situation, and allowed the assessee's appeal, annulling the impugned assessment proceedings.
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