S. 147 : Reassessment-Rectification proceedings initiated but not rectified-Reassessment proceedings initiated for same reasons-Held to be not valid. [S. 148, 154]
Morgan Ventures v. Dy. CIT (2022) 94 ITR 15 (Delhi)(Trib.)S. 147 : Reassessment-Rectification proceedings initiated but not rectified-Reassessment proceedings initiated for same reasons-Held to be not valid. [S. 148, 154]
Morgan Ventures v. Dy. CIT (2022) 94 ITR 15 (Delhi)(Trib.)S. 147 : Reassessment-Business connection-No new tangible material-Reassessment is bad in law. [S. 9(1)(i), 148]
Bentley Nevada Inc. v. DCIT (2022) 194 ITD 10 / 94 ITR 503 (Delhi)(Trib.)S. 147 : Reassessment-After the expiry of four years-Search and Seizure-General information from Investigation wing-No failure to disclose material facts-Re assessment not valid. [S. 148]
Prakash Chand Kothari v. Dy. CIT (2022) 94 ITR 49 (Jaipur)(Trib.)S. 145 : Method of accounting-Estimation of income in an arbitrary, capricious, and wild manner is not permitted in the eyes of the law and must be on a reasonable basis in congruent to the result of the prior previous years. [S. 145(3)]
ITO v. Bhagchand Jain (2022) 94 ITR 472 / 217 TTJ 202 (Jaipur)(Trib.)S. 145 : Method of accounting-Disputed amount-The tax paid in subsequent year-Double taxation-Same income cannot be taxed twice. [S. 4,5]
ACIT v. Uttaranchal Jal Vidyut Nigam Ltd. (2022) 94 ITR 435 (Delhi)(Trib.)S. 144 : Best judgment assessment-Estimation of income must be on reasonable basis in congruent to the result of the prior previous years-Principle of consistency must be followed. [S. 143(3)]
DCIT v. Bridge & Building Construction Co. (P.) Ltd. (2022) 94 ITR 515 (Kol.)(Trib.)S. 143(3) : Assessment-Computation-Income from other sources-Mistake in computation sheet-Directed to take correct figure thereafter to compute tax payable which should be nil. [S. 144C(13)]
Timblo Shipyards P. Ltd. v. NEAC (2022) 94 ITR 53 (SN) (Mum.)(Trib.)S. 143(3) : Assessment-Deduction of tax at source-Mismatch-Income declared no deduction of tax at source claimed-Deletion of addition is proper. [Form No. 26AS]
ACIT v. Silver Jubilee Motors Ltd. (2022) 94 ITR 19 (Trib.) (SN) (Pune)(Trib.)S. 143(3) : Assessment-Limited scrutiny-Disallowance of deduction not subject matter of limited scrutiny-Addition deleted-Interest expenditure-No loan taken during year-Interest disallowance is not valid when no disallowance was made in earlier years or subsequent years. [S. 57]
Dharam Bhushan Jain v. ACIT (2022) 94 ITR 1 (Delhi)(Trib.)S. 143(3) : Assessment-Search-Merely because a hard disk belonging to assessee was found and seized from business premises of assessee, gives no ground for addition to the AO, when no incriminating or corroborative documents have emanated therefrom or otherwise. [S. 132, 292]
ACIT v. Lepro Herbals (P.) Ltd. (2022) 94 ITR 225 /216 TTJ 682 / 215 DTR 233 (Delhi)(Trib.)