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...
Reopening of assessment was challenged because the stated grounds-an alleged clerical mistake in inventory computations and unexplained cash deposits-no longer survive: the inventory-based addition has since been deleted by the ITAT and the Revenue does not dispute that deletion, and the cash deposits were specifically queried and satisfactorily explained with the cash book produced during original scrutiny, leading the AO then to make no addition. The article concludes that reassessment here amounts to a mere change of opinion and is therefore not justified.
Reopening of assessment was challenged because the stated grounds-an alleged clerical mistake in inventory computations and unexplained cash deposits-no longer survive: the inventory-based addition has since been deleted by the ITAT and the Revenue does not dispute that deletion, and the cash deposits were specifically queried and satisfactorily explained with the cash book produced during original scrutiny, leading the AO then to make no addition. The article concludes that reassessment here amounts to a mere change of opinion and is therefore not justified.
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