Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
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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