S. 147 : Reassessment-Bogus purchases-Cash credits-Accommodation entries-Information from Investigation wing-Not recorded his own satisfaction-Reassessment order is quashed. [S. 68 148]
S. 147 : Reassessment-Bogus purchases-Cash credits-Accommodation entries-Information from Investigation wing-Not recorded his own satisfaction-Reassessment order is quashed. [S. 68 148]
S. 144C : Reference to dispute resolution panel-Unexplained money-Draft assessment order-Order passed in violation of directions of DRP-Nullity and bad in law.[S.69A]
S. 144C : Reference to dispute resolution panel-Order in the name of amalgamating company-Non existent entity-Assessment proceedings based on an invalid draft assessment order were void ab initio and quashed. [S. 143(3)]
S. 144C : Reference to dispute resolution panel-Option to file objection waived-Draft assessment order-Mandatory requirement of forwarding a draft assessment order could not be done away with-Order is quashed.
S. 143(3) : Assessment-Purchase of property-Joint owners-Disclosed in the books of accounts of the Company-Transaction cannot be held to be Benami. [Prohibition of Benami Property Transactions Act, 1988, S. 2(9),24)
S. 115JB : Company-Book profit-Upward adjustment-Amount withdrawn from reserve/provision which stood credited in profit and loss account for year and was reduced while computing book profit-Adjustment is deleted. [S. 145]
S. 115JB : Company-Book profit-Financial corporation-Not a company-Not liable to be assessed to book profit.[S. 2(17), 2(26), Companies Act, 1956, S. 129]
S. 115BBE : Tax on specified income-Determination of tax in certain cases-Permanent disability- Blind or physically handicapped persons-Disallowance of claim-Tax cannot be imposed under section 155BBE of the Act-Provisions of section 69A cannot be invoked in respect of incorrect claim of deduction under section 80G-Tax cannot be imposed under section 155BBE of the Act. [S. 68 to 69, 69A 80G, 80U]
S. 90 : Double taxation relief-Foreign tax credit-Mere delay in filing Form No. 67 as per provisions of rule 128(9), under will not preclude assessee from claiming benefit of foreign tax credit in respect of tax paid outside India.[S.90A, R. 128(9), Form No.67]
S. 80G : Donation-Additional evidence-Rectification application is pending-Matter is remanded back to Assessing Officer to examine assessee’s claim with reference to supporting evidence filed by it. [S. 154]