https://www.taxtmi.com/caselaws?id=784279 Reassessment under ss. 147/148 was upheld as valid because the notice and reassessment were issued and completed in conformity with statutory requirements; consequently, the reopening was sustained. Disallowance under s. 40(a)(ia) for TDS defaults was restricted to avoid double disallowance where a disallowance for the same default had already been made; the AO was directed to reduce the duplicated amount and the balance disallowance was confirmed, rejecting absence of payee-tax evidence and holding the 30% amendment prospective (inapplicable pre-AY 2015-16). Ad hoc disallowance of 5% of cash purchases was deleted as unsupported by incriminating material, specific defects, or s. 40A(3) violation; deletion was upheld. Disallowances for business promotion and travel were deleted as double additions and personal-use disallowance is impermissible for a company; deletion was upheld. The assessment was ultimately quashed for mechanical, omnibus approval under s. 153D vitiating the order. en-us Fri, 19 Dec 2025 00:00:00 +0530 Wed, 31 Dec 2025 14:23:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784279 Reassessment under ss. 147/148 was upheld as valid because the notice and reassessment were issued and completed in conformity with statutory requirements; consequently, the reopening was sustained. Disallowance under s. 40(a)(ia) for TDS defaults was restricted to avoid double disallowance where a disallowance for the same default had already been made; the AO was directed to reduce the duplicated amount and the balance disallowance was confirmed, rejecting absence of payee-tax evidence and holding the 30% amendment prospective (inapplicable pre-AY 2015-16). Ad hoc disallowance of 5% of cash purchases was deleted as unsupported by incriminating material, specific defects, or s. 40A(3) violation; deletion was upheld. Disallowances for business promotion and travel were deleted as double additions and personal-use disallowance is impermissible for a company; deletion was upheld. The assessment was ultimately quashed for mechanical, omnibus approval under s. 153D vitiating the order. Case-Laws Income Tax Fri, 19 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784279