Religious purpose exclusion versus charitable purpose: non overriding religious objects do not attract Explanation 3, registration directed under sect...
Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
Validity of reassessment notice under s.147/s.148: held that Range head has concurrent jurisdiction and undated/unsigned reasons were not fatal where covering letter carried DIN - notice valid. Addition under s.2(22)(e): transactions characterized as ordinary course share trading; reliance on precedent and CBDT Circular supports deletion of deemed dividend - addition deleted. Disallowance under s.14A: no investment existed in books, AO's presumption defective - deletion sustained. Short-term capital loss on alleged property sale: absence of transfer evidence and contrived transactions found; CIT(A)'s relief set aside and AO's addition confirmed. Additions under ss.41(1) and 68: CIT(A)'s deletions sustained; other expense disallowances for non-production of parties overturned - mixed outcomes. - ITAT
Validity of reassessment notice under s.147/s.148: held that Range head has concurrent jurisdiction and undated/unsigned reasons were not fatal where covering letter carried DIN - notice valid. Addition under s.2(22)(e): transactions characterized as ordinary course share trading; reliance on precedent and CBDT Circular supports deletion of deemed dividend - addition deleted. Disallowance under s.14A: no investment existed in books, AO's presumption defective - deletion sustained. Short-term capital loss on alleged property sale: absence of transfer evidence and contrived transactions found; CIT(A)'s relief set aside and AO's addition confirmed. Additions under ss.41(1) and 68: CIT(A)'s deletions sustained; other expense disallowances for non-production of parties overturned - mixed outcomes. - ITAT
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