Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
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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