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...
The dominant issue was whether the limitation for passing the final assessment order in a DRP case is governed by section 153(1) read with section 153(4) or by section 144C(13). Relying on coordinate bench precedent that followed HC rulings, the Tribunal held that statutory limitation must be computed under section 153(1) r/w section 153(4), fixing the last permissible date as 30.09.2021. Since the final assessment order was passed on 07.07.2023, it was held to be time-barred and was quashed, resulting in allowance of the taxpayer's appeal. - ITAT
The dominant issue was whether the limitation for passing the final assessment order in a DRP case is governed by section 153(1) read with section 153(4) or by section 144C(13). Relying on coordinate bench precedent that followed HC rulings, the Tribunal held that statutory limitation must be computed under section 153(1) r/w section 153(4), fixing the last permissible date as 30.09.2021. Since the final assessment order was passed on 07.07.2023, it was held to be time-barred and was quashed, resulting in allowance of the taxpayer's appeal. - ITAT
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