Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
Addition under Section 56(2)(vii) was challenged where two land parcels acquired below Stamp Duty Value were treated as stock-in-trade; lower authorities sustained the addition due to the assessee's failure to produce books and purchase-sale records, creating an evidentiary deficit. The tribunal, without deciding the asset classification on merits, set aside the order and remanded the matter to the AO for de novo adjudication, directing examination of books and financial-statement treatment, verification of the applicability of CBDT Circular No. 1/2011 and relevant precedents on the definition of "property", and affording the assessee a reasonable, effective opportunity to be heard.
Addition under Section 56(2)(vii) was challenged where two land parcels acquired below Stamp Duty Value were treated as stock-in-trade; lower authorities sustained the addition due to the assessee's failure to produce books and purchase-sale records, creating an evidentiary deficit. The tribunal, without deciding the asset classification on merits, set aside the order and remanded the matter to the AO for de novo adjudication, directing examination of books and financial-statement treatment, verification of the applicability of CBDT Circular No. 1/2011 and relevant precedents on the definition of "property", and affording the assessee a reasonable, effective opportunity to be heard.
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