S. 147 : Reassessment-Pursuant to direction of Tribunal-No direction of Tribunal to tax sum in question in hands of company-Reopening of assessment to bring sum to tax in hands of company is not sustainable. [S. 132(4), 148, 150]
S. 147 : Reassessment-Pursuant to direction of Tribunal-No direction of Tribunal to tax sum in question in hands of company-Reopening of assessment to bring sum to tax in hands of company is not sustainable. [S. 132(4), 148, 150]
S. 147: Reassessment-Depreciation-Assets purchased from Subsidy-Change of opinion-Reassessment is bad in law-Subsidy-Renewable energy scheme to set up small hydro projects-Capital in nature-Not income-[S. 2(24)(xviii), 115JB, 143(3), 148]
S. 147 : Reassessment-Notice in the name of dead person-Expired before passing of the assessment order-No notice is served on legal heir-Assessment is non est and bad in law.[S. 143(1),144, 148, 159]
S. 145 : Method of accounting-Accrual income-Electricity company-Late payment surcharge-Taxed in earlier and subsequent years on receipt basis-Accounting Standard 9-Not to be taxed on accrual basis.[S. 4]
S. 145 : Method of accounting-No defects in the books of account-Ad-hoc estimate of profit is not justified. [S. 133A, 145 (3)
S. 144C : Reference to dispute resolution panel-Final assessment order was passed without incorporating directions of Dispute Resolution Panel-Matter remanded to Assessing Officer to pass order incorporating Dispute Resolution Panel’s directions. [S.144C(13)]
S. 144C : Reference to dispute resolution panel-Non-Resident-Assessment-Eligible assessee —Order under Section 92CA is not prerequisite in case of Non-resident.[S.92CA]
S. 143(3): Assessment-Document Identification Number-Circular making generation and quoting of mandatory —Assessment order invalid and deemed to have never been passed.[S.119]
S. 143(3): Assessment-Document Identification Number-Failure to allot and mention in assessment order-Assessment order deemed never to have been passed —Central Board Of Direct Taxes Circular No. 19 Of 2019, Dated 14-8-2019-Order is bad in law-Additional ground is admitted-Order is quashed. [S.153A, 254(1)]
S. 143(3): Assessment-Income from undisclosed sources-Documents seized in the course of search-Real estate broker-Addition of peak of transactions reflected in seized material is not sustainable-Estimate of profit of 1 percent of gross receipts is held to be proper. [S. 131, 132, 133(6)]