S. 147 : Reassessment-After the expiry of four years-Recorded reasons must indicate the manner in which the Assessing Officer has come to the conclusion that income chargeable to tax has escaped assessment-Reason recorded cannot be substituted-Reassessment Notice was quashed. [S. 148, Art. 226]
S. 147 : Reassessment-After the expiry of four years-Business expenditure-Advertisement and marketing expenditure-Change of opinion-Reassessment notice was quashed. [S. 37(1), 148, Art. 226]
S. 144B : Faceless Assessment-Order passed without show cause and draft assessment order-Order was quashed. [S. 143(3), 144B(xi)(b), Art. 226]
S. 144B : Faceless Assessment-Order passed without considering the reply-Incorrect affidavit by the Assessing Officer-Show cause notice was issued for perjury proceedings-Cost of Rs 10000 was imposed payable to PM Cares Fund-Order was set aside. [Art. 226]
S. 144B : Faceless Assessment-Order passed without providing the draft assessment order-Order was quashed-Directed the revenue to prepare draft assessment order as prescribed by law. [Art. 226]
S. 144B : Faceless Assessment-Personal hearing was not granted-Violation of principle of natural justice-Assessment order was quashed-Directed to grant an opportunity of hearing by way of Video Conferencing. [S. 144B(7), 144B(9), Art. 226]
S. 143(3) : Assessment-Show cause notice is mandatory-Assessing Officer is expected to crystalise the issues and issue a show cause notice setting out the issues and solicit the response of the assessee-Assessment order was set aside. [Art. 226]
S. 139 : Return of income-Revised return-Permitted to file revised return in an electronic mode once the direction of the NCLT was communicated. [Art. 226]
S. 115-O : Domestic companies-Tax on distributed profits-Non-Obstante clause-Overriding effect-Amount distributed or paid by way of dividend falls under the category of profits under section 50 of the SIDBI Act-Not liable to pay additional tax. [SIDBI Act, S. 29(2), Unit Trust India Act, 1963, S. 32]
S. 72 : Carry forward and set off of business losses-Delayed furnishing of ITR-V-Order of Tribunal allowing the carry forward of losses was affirmed. [S. 80, 139]