S. 263 : Commissioner-Revision of orders prejudicial to revenue-Expenditure on scientific research-Conducted detailed enquiries into claim of deduction-Revision order is quashed. [S. 35(2AB), 143(3)]
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Expenditure on scientific research-Conducted detailed enquiries into claim of deduction-Revision order is quashed. [S. 35(2AB), 143(3)]
S. 251 : Appeal-Commissioner (Appeals)-Powers-Dismissal of appeal ex parte-CIT(A)has no power to dismiss the appeal without discussing the appeal on merits-Matter is remanded to the CIT(A) to decide the grounds on merits. [S. 250(1)]
S. 249 : Appeal-Commissioner (Appeals)-Form of appeal and limitation-No admitted income-Cash deposited in the Bank-The proviso also provides that when there is good and sufficient reasons, then the appeal can still be admitted-Matter is restored to the CIT(A) to adjudicate the appeal on merits in accordance with law. [S. 69A, 249 (4)(b), 250]
S. 153C : Assessment-Income of any other person-Search year-Wrongly applied the provision of Section 153C by the CIT(A) matter is remanded to the file of CIT(A) to deecide the issue on merits-Application for adjournment is rejected. [S. 132, 143(3)255, ITAT R,1963, R. 23]
S. 153A: Assessment-Search-Undisclosed income-Document referred to and relied upon by the AO does not bear any signature of the assessee-Addition is deleted-Appellate Tribunal-Delay of 702 days in filing the appeal is condoned. [S. 254(1)]
S. 153A: Assessment-Search-Approval-Jt. CIT has given certain specific instructions to the AO- Mandate is complied with.[S. 143(3)153D]
S. 148 : Reassessment-Notice-Limitation-First notice under s. 148 was issued on 30th June, 2021-Since the notice was issued after 1st April, 2021, amended provisions effective from 1st April, 2021 were applicable-Notice is within limitation period. [S. 147, 148A(d)]
S. 147 : Reassessment-Assessment order passed by non-jurisdictional AO-Invalid transfer on request of assessee-Mandate of law is not followed-Notice and order is bad in law.[S.114B, 127(4), 139A(5), 143(3), 148, 272B]
S. 147 :Reassessment-Information received from Investigation Wing-Return was processed u/s143(1)-Survey-Accommodation entries-Reassessment is justified-On merit the matter is remanded to estimate of gross profit as applicable to genuine purchases. [S. 69C, 133A, 143(1)]
S. 147:Reassessment-Limitation-Non-resident-No reference to TPO-The time-limit for completing the assessment under was available upto 31st March, 2023-Order passed on 8 th January, 2024-Barred by limitation-Additional legal ground on limitation is admitted. [S.92CA, 144C(13), 148 153(2), 153(4), 254(1)]