S. 153C : Assessment-Income of any other person-Search and seizure-Loose sheet-Not form part of books of account-diaries/loose sheets-Order of High Court quashing the addition is affirmed-SLP of Revenue is dismissed.[S. 132, Art. 136]
S. 153C : Assessment-Income of any other person-Search and seizure-Loose sheet-Not form part of books of account-diaries/loose sheets-Order of High Court quashing the addition is affirmed-SLP of Revenue is dismissed.[S. 132, Art. 136]
S. 153A : Assessment-Search or requisition-No incriminating material-Deemed dividend-Deletion of addition is affirmed-No substantial question of law.[S. 2(22)(e), 132, 260A]
S. 153A : Assessment-Search or requisition-Block period of six years-No incriminating material for the relevant assessment year-Order of CIT (A) deleting the addition is affirmed-Order of Tribunal is set aside. [S. 132,260A]
S. 151 : Reassessment-Sanction for issue of notice-Beyond three years-Sanction-Specified Authority-Sanction from Principal Commissioner-Not from Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General and not under section 151(i)-Prior approval was taken from Principal Commissioner in terms of section 151(i) and not by specified authority under section 151(ii)-Order as well as notice issued under section 148 is bad in law hence quashed and set aside. [S. 148, 148A(b) 148A(d), 151 (i) 151 (ii), Art. 226]
S. 149 : Reassessment-Time limit for notice-Assessing Officer had proceeded without jurisdiction by applying amended provisions of section 149 to case in hand when he issued notice on 25-7-2022 overlooking fact that limitation had already expired on 31-3-2020-Reopening notice issued under section 148 is quashed.[S. 148, 149(1)(b) Art. 226]
S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained money-Sale consideration received in cash-Sale by Power of Attorney holder-Since a detailed adjudication on merits of information available with Assessing Officer and defence set up by assessee is not contemplated at stage of passing an order under section 148A(d)-Writ petition is dismissed.[S. 69A, 148, 148A(b), 148A(d), Power of Attorney Act, 1882, Art. 226,]
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Amounts of investments not fully disclosed in books of account-Report from District Valuation Officer (DVO)-Fixed asset and Capital WIP-Failure to apply mind-Reassessment notice and order disposing the objection is quashed.[S. 48, 69A, 148, Art. 226]
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained investments-Violation of principle of natural justice-Order passed without considering the documents submitted by the assessee-Assessment order is set aside and matter is remanded for reconsideration from stage of reply to show cause notice cum draft assessment order.[S. 69, 148, 148A(b), 148A(d), Art. 226]
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained investments-Immovable property-Added entire sale consideration-[S. 69, 148, 148A(b), 148A(d), Art. 226]
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Officer who has issued the notice and heard the matter-Order is passed by the Officer who has not heard the matter-Order and notice is set aside.[S. 148, 148A(b), 148A(d), Art. 226]