Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
Reopening of assessment beyond four years was held invalid because the assessee had disclosed complete books, audited financials, and ledgers for machinery rent, purchases, and carriage expenses during the original scrutiny, and the AO had examined cash payments and made an ad hoc disallowance after applying mind. The alleged Section 68 discrepancy in an unsecured loan ledger was found to be a transparent accounting misposting of a bank transfer by a partner, with no impact on cash balance or total liabilities, later rectified. In the absence of any fresh tangible material, the reopening amounted to a mere change of opinion barred by law; notice under Section 148 was quashed and the appeal was allowed - ITAT
Reopening of assessment beyond four years was held invalid because the assessee had disclosed complete books, audited financials, and ledgers for machinery rent, purchases, and carriage expenses during the original scrutiny, and the AO had examined cash payments and made an ad hoc disallowance after applying mind. The alleged Section 68 discrepancy in an unsecured loan ledger was found to be a transparent accounting misposting of a bank transfer by a partner, with no impact on cash balance or total liabilities, later rectified. In the absence of any fresh tangible material, the reopening amounted to a mere change of opinion barred by law; notice under Section 148 was quashed and the appeal was allowed - ITAT
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