Condonation of Delay denied: communication lapses and corporate restructuring found insufficient; prolonged inaction and lack of bona fides led to ref...
Export Support intervention INSIGHT launched to provide non financial capacity building, trade intelligence and pilot support with defined funding and...
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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