Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
A prior unsuccessful revision under section 264 did not bar the assessee from pursuing the statutory appellate remedy, as the right of appeal is a substantive statutory right and no provision prohibited recourse to appeal after an earlier bona fide attempt at revision. The Tribunal also accepted sufficient cause for the delay before the first appellate authority and rejected the non-maintainability finding. On merits, cash deposits made during demonetisation were supported by bank records and supporting documents showing withdrawals for house construction and their later redeposit, so the addition under section 69A was held to rest on mere guesswork and was deleted.
A prior unsuccessful revision under section 264 did not bar the assessee from pursuing the statutory appellate remedy, as the right of appeal is a substantive statutory right and no provision prohibited recourse to appeal after an earlier bona fide attempt at revision. The Tribunal also accepted sufficient cause for the delay before the first appellate authority and rejected the non-maintainability finding. On merits, cash deposits made during demonetisation were supported by bank records and supporting documents showing withdrawals for house construction and their later redeposit, so the addition under section 69A was held to rest on mere guesswork and was deleted.
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