Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
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Where the assessing officer assumed and exercised jurisdiction based on material seized during search, the non obstante effect of Section 153C prevents initiation of parallel reassessment proceedings under Sections 147/148; therefore reopenings under Sections 147/148 in such circumstances are invalid and must be quashed. A Revenue reliance on a High Court decision was rejected where intervening higher court proceedings left that judgment non final. The tribunal confirmed the appellate finding invalidating the reassessment and dismissed the Revenue appeal, leaving the substantive additions undecided on merits.
Where the assessing officer assumed and exercised jurisdiction based on material seized during search, the non obstante effect of Section 153C prevents initiation of parallel reassessment proceedings under Sections 147/148; therefore reopenings under Sections 147/148 in such circumstances are invalid and must be quashed. A Revenue reliance on a High Court decision was rejected where intervening higher court proceedings left that judgment non final. The tribunal confirmed the appellate finding invalidating the reassessment and dismissed the Revenue appeal, leaving the substantive additions undecided on merits.
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