Fraudulent trading requires cogent evidence of intent to defraud; ordinary-course payments protected, except post-insolvency withdrawals must be resto...
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...
The sole issue is validity of reassessment where notices under section 143(2) were issued manually without a computer-generated DIN. Relying on the CBDT circular making DIN mandatory from 01.10.2019 and permitting manual issue only with recorded reasons and prior written approval of CCIT/DGIT, the tribunal found Revenue could not produce recorded reasons or prior approval. Consequently the 143(2) communications are invalid and deemed never issued; assumption of jurisdiction under section 148 is vitiated and reassessment is quashed as void ab initio. - ITAT
The sole issue is validity of reassessment where notices under section 143(2) were issued manually without a computer-generated DIN. Relying on the CBDT circular making DIN mandatory from 01.10.2019 and permitting manual issue only with recorded reasons and prior written approval of CCIT/DGIT, the tribunal found Revenue could not produce recorded reasons or prior approval. Consequently the 143(2) communications are invalid and deemed never issued; assumption of jurisdiction under section 148 is vitiated and reassessment is quashed as void ab initio. - ITAT
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