Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Section 153A, not section 147, governed reassessment because the additions were stated to arise from search material; the AO's assumption of jurisdiction under section 147 for AY 2011-12 was therefore invalid and the reassessment was quashed. For AY 2012-13 and AYs 2014-15 to 2018-19, additions based on alleged bogus capital gains, commission and cash loans were deleted because section 153A permits additions only on incriminating material found in the assessee's own search; third-party search material, even if confronted to the assessee, does not satisfy that requirement and would instead implicate section 153C. Notional interest additions were also deleted as derivative and unsupported by any real accrual or receipt.
Section 153A, not section 147, governed reassessment because the additions were stated to arise from search material; the AO's assumption of jurisdiction under section 147 for AY 2011-12 was therefore invalid and the reassessment was quashed. For AY 2012-13 and AYs 2014-15 to 2018-19, additions based on alleged bogus capital gains, commission and cash loans were deleted because section 153A permits additions only on incriminating material found in the assessee's own search; third-party search material, even if confronted to the assessee, does not satisfy that requirement and would instead implicate section 153C. Notional interest additions were also deleted as derivative and unsupported by any real accrual or receipt.
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