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...
Whether interest on enhanced compensation is taxable or exempt: Holding that plain language of s.56(2)(viii) read with s.145B(1) brings interest on enhanced compensation under "income from other sources," and s.10(37) covers only compensation (not interest); outcome-interest is exigible to tax and exemption claim fails. Whether revision u/s 263 was justified: PCIT found AO failed to make requisite statutory and judicial inquiries (including jurisdictional HC precedents), rendering the assessment erroneous and prejudicial; outcome-revision u/s 263 was valid and recomputation under s.56(2)(viii) r.w.s.145B(1) with s.57(iv) deduction affirmed. - ITAT
Whether interest on enhanced compensation is taxable or exempt: Holding that plain language of s.56(2)(viii) read with s.145B(1) brings interest on enhanced compensation under "income from other sources," and s.10(37) covers only compensation (not interest); outcome-interest is exigible to tax and exemption claim fails. Whether revision u/s 263 was justified: PCIT found AO failed to make requisite statutory and judicial inquiries (including jurisdictional HC precedents), rendering the assessment erroneous and prejudicial; outcome-revision u/s 263 was valid and recomputation under s.56(2)(viii) r.w.s.145B(1) with s.57(iv) deduction affirmed. - ITAT
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