S. 153C : Assessment-Income of any other person-Search-Approval of draft assessment-Sanction granted without application of mind-Order is bad in law. [S.132, 153D]
S. 153C : Assessment-Income of any other person-Search-Approval of draft assessment-Sanction granted without application of mind-Order is bad in law. [S.132, 153D]
S. 153C : Assessment-Income of any other person-Search-Assessment-Document identification Number (DIN)-CBDT Circular No. 19 of 2019, dated 14-8-2019-Assessment order manually without generating any DIN number-Non-est in eyes of law. [S. 143(3)]
S. 147 : Reassessment-Unaccounted on-money in cash-Date of payment as 5-11-2013-No addition can be made for the relevant assessment year.[S.69 , 148]
S. 147 : Reassessment-Share application-Accommodation-No proof of service of reasons recorded being supplied to assessee, reassessment-Reassessment is quashed-Information in his possession, in form of tangible material from Directorate of Investigation (DDIT) during third-party search that income of assessee had escaped assessment-Non-existence of a particular entity-Succession to business otherwise than on death-[S. 68, 148, 153C, 170, 292B]
S. 147 : Reassessment-Income deemed to accrue or arise in India-Interest-Failure to deduct tax deduct at source-Redemption premium paid-Income had not arisen in India in hands of recipient/non-resident and there was no obligation on part of BFL to deduct tax at source on payment of interest-Re assessment is quashed. [S. 5(2), 6, 9(1(vi) 148, 201(IA)]
S. 147 : Reassessment-With in four years-Change of opinion-Scientific research expenditure-No new material-Reassessment is quashed.[S. 35(2AB), 143(3), 148]
S. 145 : Method of accounting-Fall in profit-Detailed explanation is furnished-Estimate profit rate at 4 per cent without rejecting books of account was not in accordance with law.
S. 145 : Method of accounting-Undervaluation of stock-Fall in GP-Allegations made by Special Auditor-Rejection of books of account is unjustified.
S. 144C : Reference to dispute resolution panel-Direction issued by DRP is binding on the Assessing Officer.[S.144C(10)]
S. 144C : Reference to dispute resolution panel-Delay in filing object against draft assessment order-Appeal filed against draft assessment order is not maintainable-No power under section 144C for DRP to condone delay in filing objections either before it or before Assessing Officer. [S. 92CA, 144C(1), 144C(2b)(ii), 144C(3), 253 (1)]