S. 153A : Assessment – Search-Industrial undertaking – Developer -Deduction can be claimed in return pursuant to notice under S. 153A of the Income -tax Act [S. 80IA (4)(i), 139(4) ]
S. 153A : Assessment – Search-Industrial undertaking – Developer -Deduction can be claimed in return pursuant to notice under S. 153A of the Income -tax Act [S. 80IA (4)(i), 139(4) ]
S. 151 : Reassessment – Sanction for issue of notice – Failure on part of Assessing Officer to take sanction of appropriate authority would go to very root of validity of assumption of jurisdiction by Assessing Officer [ S. 147, 148,292B ]
S. 151 : Reassessment – Sanction for issue of notice -Reassessment proceedings couldn’t be quashed just because AO had obtained prior approval from higher authority [ S. 147, 148 ]
S. 151 : Reassessment – Sanction for issue of notice –Mechanical approval was held to be bad in law [ S. 147, 148 ]
S. 151: Reassessment – After the expiry of four years – Sanction of the Chief Commissioner was a pre-condition. [ S.147,148, 149 ]
S. 151 : Reassessment – Sanction for issue of notice – After expiry of four years – Notice and proceedings was vitiated for want of specific sanction .[ S. 147, 148 ]
S. 147 : Reassessment –Clerical mistake- The object and purpose behind S. 292B is to ensure that technical pleas on the ground of mistake, defect or omission should not invalidate the assessment proceedings, when no confusion or prejudice is caused due to non-observance of technical formalities [ S. 148, 292B ]
S. 147: Reassessment- Reassessment on the basis of information received from investigation wing for alleged accommodation entries and denial by parties the reopening was held to be bad in law [ S. 148 ]
S.147: Reassessment- Failure to disclose beneficial owner of deposits in foreign Bank accounts -Reassessment was held to be justified [ S.69 , 148 ]
S.147: Reassessment — Issue was not considered in the original assessment proceedings hence reassessment was held to be valid. As regard the allowability of depreciation on stock exchange membership the matter was remanded .[ S. 32, 148 ]