Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
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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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