https://www.taxtmi.com/caselaws?id=462549 ITAT Bangalore ruled in favor of the assessee on multiple grounds. The tribunal deleted income estimation based solely on survey statements, citing constitutional provisions that tax collection requires legal authority. Regarding interest disallowance under section 36(1)(iii), the tribunal allowed deduction for funds advanced to sister concern for business purposes, applying commercial expediency test per SC precedent. The reassessment was annulled due to invalid notice under section 143(2) and procedural defects in section 148 notices, including improper timing of approval and limitation period violations. The tribunal found no change of opinion in reopening assessment. en-us Mon, 22 Mar 2021 00:00:00 +0530 Wed, 25 Jun 2025 12:01:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462549 ITAT Bangalore ruled in favor of the assessee on multiple grounds. The tribunal deleted income estimation based solely on survey statements, citing constitutional provisions that tax collection requires legal authority. Regarding interest disallowance under section 36(1)(iii), the tribunal allowed deduction for funds advanced to sister concern for business purposes, applying commercial expediency test per SC precedent. The reassessment was annulled due to invalid notice under section 143(2) and procedural defects in section 148 notices, including improper timing of approval and limitation period violations. The tribunal found no change of opinion in reopening assessment. Case-Laws Income Tax Mon, 22 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462549