S.147: Reassessment-After the expiry of four years-No failure to disclose material facts –Sham transaction-Reassessment notice and order disposing of the objection were quashed-Sanction-Non-application of mind.[S.50C, 148,151 Art. 226]
S.147: Reassessment-After the expiry of four years-No failure to disclose material facts –Sham transaction-Reassessment notice and order disposing of the objection were quashed-Sanction-Non-application of mind.[S.50C, 148,151 Art. 226]
S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Change of opinion-Notice not valid.[S. 148, Art. 226]
S. 145 : Method of accounting-Search and seizure-Assessment in Rejection of books of account-Estimation of gross profit-Restriction of gross profit to two per cent. from four per cent. by Commissioner (Appeals) confirmed by Tribunal-Order of Tribunal affirmed. [S. 132, 153A,260A]
S. 144C : Reference to dispute resolution panel-International transactions-Draft assessment order must be forwarded to assessee-Failure to pass draft assessment order would render assessment order as null and void. [S.92C, 92CA, Art. 226.]
S. 144B: Faceless Assessment Video conference-Adequate opportunity of hearing should be given to assessee.[S. 147, Art. 226]
S. 144 : Best judgment assessment-Principle of natural justice-All correspondence sent to assessee’s old address-Intimation received by assessee at new address after three years-Direction to provide opportunity of hearing.[Art. 226]
S. 144: Best judgment assessment-Estimation of unaccounted sales of finished goods manufactured out of excess scrap-Neither books of account rejected nor any evidence to support suspicion of unaccounted manufacturing and sale of finished goods-Order of Tribunal deleting additions is affirmed. [S. 260A]
S. 143(3): Assessment-Sale proceeds of agricultural land partly invested in purchasing a house site and balance deposited in bank-Alternative remedy-Appeal pending before CIT(A)-Rectification application-Writ petition dismissed.[S. 154, 156,246A, Art. 226]
S. 143(3): Assessment-Amalgamation intimated to Income-tax authorities which has merged-Assessment proceedings against non existing company not valid-Participation in the proceedings by the assessee cannot operate as an estoppel against law. [Art. 226]
S.143(3): Assessment-Principle of natural justice-Order passed without giving assessee adequate opportunity of hearing-Order is set aside.[Art. 226]