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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...
Statutory exemption under section 10(26AAB) for an Agricultural Produce Marketing Committee could not be denied merely because the PAN reflected an incorrect status as a trust. The ITAT held that the assessee's true character as an Agricultural Produce Marketing Committee was undisputed, and a mismatched PAN entry was not determinative of the legal position or a basis to tax otherwise exempt income. On that footing, the assessment orders were set aside on merits, the AO was directed to compute total income at nil, and the reopening grounds were left undecided because no taxable income survived.
Statutory exemption under section 10(26AAB) for an Agricultural Produce Marketing Committee could not be denied merely because the PAN reflected an incorrect status as a trust. The ITAT held that the assessee's true character as an Agricultural Produce Marketing Committee was undisputed, and a mismatched PAN entry was not determinative of the legal position or a basis to tax otherwise exempt income. On that footing, the assessment orders were set aside on merits, the AO was directed to compute total income at nil, and the reopening grounds were left undecided because no taxable income survived.
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