S. 151 : Reassessment-Sanction for issue of notice-Order passed by ignoring the revised return filed by assessee-No satisfaction recorded by Pr. CIT before granting approval-Reassessment order was quashed and set aside. [S. 147, 148]
S. 151 : Reassessment-Sanction for issue of notice-Order passed by ignoring the revised return filed by assessee-No satisfaction recorded by Pr. CIT before granting approval-Reassessment order was quashed and set aside. [S. 147, 148]
S. 115BAA: Tax on income of certain domestic companies-Determination of tax in certain cases-Failure to file Form No 10IC-Assessee was to be directed to file Form No. 10IC within one month from the date of receipt of this order.[Form No 10IC]
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained cash-Demonetisation-Recorded reason for reopening under section 148A(d) was found incorrect-Addition made on the basis of recorded reasons was deleted by CIT(A)-No further additions beyond the original reason could be sustained-All additions made without jurisdiction were deleted.[S.69A, 147, 148, 148A(b), 148A(d)]
S. 147: Reassessment-Legal representatives-Information from Investigation Wing-Assessment orders were framed in the name of deceased assessee-Reopening notice and assessment orders were quashed and set aside. [S. 148, 159]
S. 147: Reassessment-Change of opinion-Interest-free advances-No fresh information-Reassessment was quashed-Notional Interest-Order of CIT(A) deleting the notional interest was affirmed. [S. 4, 28(i),37(1), 143(3), 148]
S. 145: Method of accounting-Estimation of income-Income recognition-Toll contractor awarded with a 15-year toll collection and maintenance contract-Only net consideration as income instead of gross receipts and expenses-Assessing Officer was not right in taxing gross income and ignoring estimated maintenance costs.[S. 4, 5]
S. 145: Method of accounting-Project completion method (PCM)-Real estate developers-Consistently accepted-Application of Percentage Completion Method by Assessing Officer was unjustified-Survey-Merely on basis of a statement recorded during survey proceedings under sections 133A/131, without any corroborative evidence, could not be sustained. [S.131, 133A]
S. 144C: Reference to dispute resolution panel-Limitation-Final assessment order dated 28-06-2022 was passed after DRP directions on 22-4-2022-Beyond the time limit prescribed under section 144C(13) Barred by limitation-Order was quashed.[S.92CA, 144C(13)]
S. 80P: Co-operative societies-Commission income from MSEDCL Bill Collection-Services rendered to members-Entitled to exemption. [S.80P(2) (c)]
S. 115BAA: Tax on income of certain domestic companies-Determination of tax in certain cases-Total income-Long Term Capital Gain, would be 22 per cent as per section 115BAA and not 20 per cent under section 112. [S. 112]