Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
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Where reassessment was initiated within four years, the AO was not required to quantify the alleged escapement in the recorded reasons; reopening to verify impugned transactions was therefore valid. Consequently, the assessee's objection that no addition could be made for purchases from one of the concerned vendors on the ground that such transactions were outside the reopening reasons was rejected, and the AO was held competent to examine and make additions on those purchases. On the genuineness of such purchases and the appropriate disallowance, profit was directed to be estimated at 5% higher than the GP rate disclosed for the year, after granting opportunity of hearing, resulting in partial relief. - ITAT
Where reassessment was initiated within four years, the AO was not required to quantify the alleged escapement in the recorded reasons; reopening to verify impugned transactions was therefore valid. Consequently, the assessee's objection that no addition could be made for purchases from one of the concerned vendors on the ground that such transactions were outside the reopening reasons was rejected, and the AO was held competent to examine and make additions on those purchases. On the genuineness of such purchases and the appropriate disallowance, profit was directed to be estimated at 5% higher than the GP rate disclosed for the year, after granting opportunity of hearing, resulting in partial relief. - ITAT
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