S. 194C : Deduction at source-Contractors-Payment made to agency as per direction of Karnataka Government-Deletion of addition is held to be justified.
S. 194C : Deduction at source-Contractors-Payment made to agency as per direction of Karnataka Government-Deletion of addition is held to be justified.
S. 153A : Assessment-Search-Participating in assessment proceedings-New plea stating that there was no search only survey was rejected-Assessment based on the statement in the course of search proceedings-Loose sheet fall within the definition of document-Rejection of request for cross examination will not amount to violation of principles of natural justice-Assessment order passed cannot be held to be without authority of law-Request for copies of statements made will have to be made by the person from whose custody any books of account or other documents were seized. [S. 132, 132(4), 132A, 133A, Art. 226]
S. 153A : Assessment-Search-Block assessment-Statement of third person recorded u/s.132(4) does not constitute incriminating material-Opportunity of cross examination was not provided-Absence of any incriminating documents found in the course of search action-Deletion of addition is held to be justified. [S. 132, 132(4), 153C]
S. 147 : Reassessment-After the expiry of four years-Expenditure for earning exempt income-No failure to disclose material facts-Notice is not valid. [S. 14A, 148, Art. 226]
S. 147 : Reassessment-After the expiry of four years-No new material-Notice to increase quantum of disallowance is held to be not valid. [S. 14A, 148, Art. 226]
S. 147 : Reassessment-After the expiry of four years-Assessment without scrutiny-Report of investigation wing-Reassessment was held to be valid. [S. 133, 143(1), 148, Art. 226]
S. 144C : Reference to dispute resolution panel-Selection for scrutiny-Draft assessment order-Participating in assessment proceedings-Notice by TPO and draft assessment order is held to be valid. [Art. 226]
S. 144C : Reference to dispute resolution panel-limitation-Notice by Dispute Resolution Panel four years after direction by Tribunal-Barred by limitation. [S. 144C(13), 153, 254 (1), Art. 226]
S. 139 : Return of income Time for filing audit report extended thrice-Prayer for writ of mandamus to extend time limit further was rejected. [S. 44AB, 119, Art. 226]
S. 132 : Search and seizure-Seizure of cash-Under investigation-Writ for release of cash is held to be not maintainable. [S. 12A, Art. 226]