Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
Benami property exclusion from the insolvency estate: Benami Act proceedings preclude IBC tribunals from reopening attachments or treating such assets...
Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
Assessee's unspent accumulated fund for AY 2009-10 assessed in AY 2015-16: primary issue whether AO rightly invoked s.147 to tax alleged escaped income. Tribunal accepts CIT(A)'s finding that unutilized funds were beyond assessee's control due to injunction and that prior years' excess expenditure could be set off against the accumulated fund following judicial precedent; therefore no income escaped assessment and assumption of jurisdiction under s.147 was unsustainable - consequence: reopening was invalid and the CIT(A)'s grant of relief on merits is upheld, so revenue's grounds are dismissed. - ITAT
Assessee's unspent accumulated fund for AY 2009-10 assessed in AY 2015-16: primary issue whether AO rightly invoked s.147 to tax alleged escaped income. Tribunal accepts CIT(A)'s finding that unutilized funds were beyond assessee's control due to injunction and that prior years' excess expenditure could be set off against the accumulated fund following judicial precedent; therefore no income escaped assessment and assumption of jurisdiction under s.147 was unsustainable - consequence: reopening was invalid and the CIT(A)'s grant of relief on merits is upheld, so revenue's grounds are dismissed. - ITAT
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