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, holding that the notice issued u/s 143(2) was unsigned and blank, thereby violating s. 282A(1) of the Act. The Tribunal found no material from the Revenue to rebut this factual defect. Consequently, the notice u/s 143(2) was declared invalid, arbitrary, and void ab initio. As the foundational notice itself was void, the AO lacked valid inherent jurisdiction to frame the assessment u/s 143(3)/147 r.w.s. 263/144B. The resultant reassessment order was therefore quashed in entirety, granting full relief to the assessee.
ITAT allowed the assessee's appeal, holding that the notice issued u/s 143(2) was unsigned and blank, thereby violating s. 282A(1) of the Act. The Tribunal found no material from the Revenue to rebut this factual defect. Consequently, the notice u/s 143(2) was declared invalid, arbitrary, and void ab initio. As the foundational notice itself was void, the AO lacked valid inherent jurisdiction to frame the assessment u/s 143(3)/147 r.w.s. 263/144B. The resultant reassessment order was therefore quashed in entirety, granting full relief to the assessee.
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