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...
Reassessment was challenged on the validity of "reasons to believe" and the requirement of a live link between material and alleged escapement of income. The recorded reasons were internally contradictory, alternately stating that no return was filed and that declared income did not match cash deposits, showing uncertainty on foundational facts. The AO relied merely on AIR data of cash deposits without any independent analysis or tangible material explaining the nature of transactions or connecting deposits to undisclosed income, rendering the reasons vague and lacking rational nexus. Consequently, the reassessment initiation was held invalid and the assessee's ground was allowed - ITAT
Reassessment was challenged on the validity of "reasons to believe" and the requirement of a live link between material and alleged escapement of income. The recorded reasons were internally contradictory, alternately stating that no return was filed and that declared income did not match cash deposits, showing uncertainty on foundational facts. The AO relied merely on AIR data of cash deposits without any independent analysis or tangible material explaining the nature of transactions or connecting deposits to undisclosed income, rendering the reasons vague and lacking rational nexus. Consequently, the reassessment initiation was held invalid and the assessee's ground was allowed - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
