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...
Where addition was made solely on an estimated net profit basis, such estimate falls outside "under-reporting of income" under section 270A(6)(b) provided the accounts are correct and complete to the satisfaction of the assessing officer; accordingly the estimation does not sustain penalty as under-reporting. Separately, penalty proceedings were vitiated by failure to specify the statutory limb of section 270A (whether clauses (2)(a)-(g) or (9)(a)-(f)), rendering initiation of penalty legally untenable; consequence: penalty deleted and appeal allowed. - ITAT
Where addition was made solely on an estimated net profit basis, such estimate falls outside "under-reporting of income" under section 270A(6)(b) provided the accounts are correct and complete to the satisfaction of the assessing officer; accordingly the estimation does not sustain penalty as under-reporting. Separately, penalty proceedings were vitiated by failure to specify the statutory limb of section 270A (whether clauses (2)(a)-(g) or (9)(a)-(f)), rendering initiation of penalty legally untenable; consequence: penalty deleted and appeal allowed. - ITAT
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