Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
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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