S. 254(2) : Appellate Tribunal-Rectification of mistake apparent from the record-Appeal which was dismissed and review petition also dismissed-Dismissal of rectification order by the Tribunal is justified. [S. 47(xiv), 260A, Art. 226]
S. 254(2) : Appellate Tribunal-Rectification of mistake apparent from the record-Appeal which was dismissed and review petition also dismissed-Dismissal of rectification order by the Tribunal is justified. [S. 47(xiv), 260A, Art. 226]
S. 151 : Reassessment-Sanction for issue of notice-Reasons for re-opening-Non application of mind-Reasons recorded and reasons supplied are different-Column 9.in left blank-Column 8 the answer given was ‘Yes’ it should have been ‘No’-Reassessment notice and order disposing objection was quashed. [S. 147, 148, Art. 226]
S. 151 : Reassessment-Sanction for issue of notice-Mechanical approval-Non-application of mind-Approval was granted was based on erroneous statement recorded in reasons-Reassessment notice and order disposing the objection was quashed. [S. 147, 148, Art. 226]
S. 151 : Reassessment-After the expiry of four years-Sanction for issue of notice-Sanction by Additional CIT is not valid-Taxation and other laws (Relaxation of Certain Provisions) Act, 2020-Not applicable-Reassessment notice and order disposing the objection was quashed. [S. 147, 148, 151(1), 151(2), Art. 226]
S. 151 : Reassessment-After the expiry of four years-Sanction for issue of notice-Sanction by Additional CIT is not valid-Taxation and other laws (Relaxation of Certain Provisions) Act, 2020-Not applicable-Reassessment notice and order disposing the objection was quashed. [S. 147, 148, 151(1), 151(2), Art. 226]
S. 148 : Reassessment-After the expiry of four years-Notice issued on non existing company-Amalgamation-Amalgamating entity ceases to exist upon the approved scheme of amalgamation and notice issued to non-existing company, is not curable defect under Section 292B of the Act.-Reassessment notice and order disposal of objection. was quashed. [S. 139(1), 147, 292B, Art. 226]
S. 147 : Reassessment-Revenue Audit-Deductions on actual payment-Two Assessing Officers disagreed with the view of Revenue Audit-Reassessment notice and order disposing the objection was quashed. [S. 43B, 148, Art. 226]
S. 147 : Reassessment-With in four years-Change of opinion-Revenue cannot improve upon the reasons in its oral argument or affidavit in reply-Reassessment notice and order disposing the objection was quashed. [S. 54, 148, Art. 226]
S. 147 : Reassessment-With in four years-Change of opinion-Change of opinion does not constitute justification and/or reasons to believe that income chargeable to tax has escaped-Survey operation-Notice of reassessment and order disposing the objection was quashed. [S. 133-A, 147, Art. 226]
S. 147 : Reassessment-Change of opinion-Order of special Bench-Carry forward and set off of business losses-Unabsorbed depreciation-Reassessment notice and order disposing the objection was quashed. [S. 32, 143(3), 147, Art. 226]