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 that reassessment u/s 147 was invalid as no addition was made on the very issue forming the recorded reasons, the assessee being treated instead as an accommodation entry provider with estimated commission income. Following binding HC precedent, the Tribunal ruled that additions on issues different from the recorded reasons could not be sustained, thereby allowing all six appeals on this primary ground. Additionally, on the alternative merits, ITAT directed that commission income be restricted to 0.50% on outstanding loan liabilities and 0.40% on sale-purchase transactions, and that intra-group transactions be excluded while computing commission income, granting partial relief in estimation.
ITAT held that reassessment u/s 147 was invalid as no addition was made on the very issue forming the recorded reasons, the assessee being treated instead as an accommodation entry provider with estimated commission income. Following binding HC precedent, the Tribunal ruled that additions on issues different from the recorded reasons could not be sustained, thereby allowing all six appeals on this primary ground. Additionally, on the alternative merits, ITAT directed that commission income be restricted to 0.50% on outstanding loan liabilities and 0.40% on sale-purchase transactions, and that intra-group transactions be excluded while computing commission income, granting partial relief in estimation.
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