Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Reassessment under section 147 cannot be sustained where the income forming the recorded basis for reopening is not ultimately added. The Tribunal applied the binding principle that "and also" is conjunctive, so the Assessing Officer must first assess or reassess the escaped income identified in the recorded reasons before bringing in any other issue. Here, the reopening was based solely on alleged unexplained cash deposits during the demonetisation period, but that issue did not survive in reassessment. The resulting disallowance of interest expenditure on a different footing was therefore held to be unsustainable and deleted.
Reassessment under section 147 cannot be sustained where the income forming the recorded basis for reopening is not ultimately added. The Tribunal applied the binding principle that "and also" is conjunctive, so the Assessing Officer must first assess or reassess the escaped income identified in the recorded reasons before bringing in any other issue. Here, the reopening was based solely on alleged unexplained cash deposits during the demonetisation period, but that issue did not survive in reassessment. The resulting disallowance of interest expenditure on a different footing was therefore held to be unsustainable and deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
