Religious purpose exclusion versus charitable purpose: non overriding religious objects do not attract Explanation 3, registration directed under sect...
Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
Reassessment validity depended on two jurisdictional defects: the sanction under section 151 was held invalid because the escapement figure shifted from Rs. 1,11,37,000 to Rs. 66,13,961 and then to Rs. 27,00,000, showing non-application of mind at the sanction stage. The Tribunal also held that reopening beyond three years was unsustainable because the surviving alleged escapement was below the Rs. 50 lakh threshold required for extended limitation under section 149(1). On these grounds, the reassessment was held untenable and the remaining issues were left open.
Reassessment validity depended on two jurisdictional defects: the sanction under section 151 was held invalid because the escapement figure shifted from Rs. 1,11,37,000 to Rs. 66,13,961 and then to Rs. 27,00,000, showing non-application of mind at the sanction stage. The Tribunal also held that reopening beyond three years was unsustainable because the surviving alleged escapement was below the Rs. 50 lakh threshold required for extended limitation under section 149(1). On these grounds, the reassessment was held untenable and the remaining issues were left open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
