Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Reassessment notice under section 148 was sustained because the Assessing Officer had independent information forming reasons to believe that income had escaped assessment by a wrong claim of deduction; accordingly reassessment proceedings were validly initiated. On the substantive claim under section 80IB(10), the notional entry arising from a joint venture accounting valuation did not represent real income in the relevant year as no approved housing project activity, sales or completion occurred; applying the real income principle and to avoid double taxation, the disallowance of the deduction was deleted and the related additions were reversed.
Reassessment notice under section 148 was sustained because the Assessing Officer had independent information forming reasons to believe that income had escaped assessment by a wrong claim of deduction; accordingly reassessment proceedings were validly initiated. On the substantive claim under section 80IB(10), the notional entry arising from a joint venture accounting valuation did not represent real income in the relevant year as no approved housing project activity, sales or completion occurred; applying the real income principle and to avoid double taxation, the disallowance of the deduction was deleted and the related additions were reversed.
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