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 the statutory limitation for passing the final assessment order under section 144C(13), i.e., whether the time limit is governed by section 153(1) read with section 153(4) or by section 144C(13) (one month from the end of the month of DRP directions). Relying on a coordinate bench ruling on an identical question, the Tribunal held that limitation must be computed under section 153(1) read with section 153(4), making the last permissible date 30.09.2023. Since the final assessment order was passed on 29.07.2024, it was held time-barred and was quashed. - ITAT
The dominant issue was the statutory limitation for passing the final assessment order under section 144C(13), i.e., whether the time limit is governed by section 153(1) read with section 153(4) or by section 144C(13) (one month from the end of the month of DRP directions). Relying on a coordinate bench ruling on an identical question, the Tribunal held that limitation must be computed under section 153(1) read with section 153(4), making the last permissible date 30.09.2023. Since the final assessment order was passed on 29.07.2024, it was held time-barred and was quashed. - ITAT
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