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 initiated within four years was upheld because, under the then-applicable s.151, sanction by the Addl. CIT was competent; the later amendment requiring PCIT approval from 01.04.2021 was held inapplicable, so the challenge to reopening failed. Addition of bank deposits as unexplained money under s.69 was remanded since the claim of linkage to professional receipts, prior cash withdrawals, third-party funds, and loans was not verified; the AO must re-examine after hearing the assessee. Notional rent on multiple properties was partly set aside: properties sold/used for profession and properties already yielding disclosed rent could not be subjected to further notional rent, while valuation for remaining properties must be based on municipal circle rates; matter remanded. LTCG computation was remanded for verification of acquisition/improvement costs on evidence. - ITAT
Reassessment initiated within four years was upheld because, under the then-applicable s.151, sanction by the Addl. CIT was competent; the later amendment requiring PCIT approval from 01.04.2021 was held inapplicable, so the challenge to reopening failed. Addition of bank deposits as unexplained money under s.69 was remanded since the claim of linkage to professional receipts, prior cash withdrawals, third-party funds, and loans was not verified; the AO must re-examine after hearing the assessee. Notional rent on multiple properties was partly set aside: properties sold/used for profession and properties already yielding disclosed rent could not be subjected to further notional rent, while valuation for remaining properties must be based on municipal circle rates; matter remanded. LTCG computation was remanded for verification of acquisition/improvement costs on evidence. - ITAT
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