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...
Reassessment under section 147 was invalid where the AO reopened the case on AIR information on the premise that the assessee was a non-PAN holder and had not filed a return, although the original return had already disclosed the property transfer, capital gains particulars and exemption claim. The Tribunal also found that the statutory notice under section 148, which confers jurisdiction for reassessment, was never served and no effective attempt at service was shown. As the reopening was also initiated beyond six years from the relevant assessment year, the reassessment was held to be without jurisdiction and void ab initio.
Reassessment under section 147 was invalid where the AO reopened the case on AIR information on the premise that the assessee was a non-PAN holder and had not filed a return, although the original return had already disclosed the property transfer, capital gains particulars and exemption claim. The Tribunal also found that the statutory notice under section 148, which confers jurisdiction for reassessment, was never served and no effective attempt at service was shown. As the reopening was also initiated beyond six years from the relevant assessment year, the reassessment was held to be without jurisdiction and void ab initio.
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