After ITAT quashed order u/s 263 passed by pcit , AO issues notice u/s 154 on same point, what can be the remedy with Assessee? Does it partake contempt of order of ITAT ? any case law?
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Assessee is a charitable trust duly registered u/s 12A of the Act. Assessment for A.Y 2015-16 was completed u/s 143(3) of the Act in October, 2017 by assessing the income in the hands of the assessee as charitable trust which is registered u/s 12A of the Act. Registration u/s 12A was cancelled in May, 2018 on the ground that the trust had indulged in illegal activities by accepting capitation fees and therefore the trust is sham or bogus, disregarding the fact that the trust is involved in educational activities and also accepted by the department in past since its inception…
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Assessee is company. Consequent to search proceedings U/SEc. 132 of the Act in the Year 2015-16, assessee co filed the Returns of income in response in response to Notice U/SEc. 153A for A.Y. 2010-11 to 2016-17. Assessment U/SEc. 153A r.w.s. 143(3) were completed on 28.12.2017 as per the income disclosed in the Return as no incriminating material was found. Thereafter Audit objection was received by the assessee co for A.Y. 2013-14, where the diffrence in sale as per assessment order and audit report under MVAT act was pointed out. The department has issued Notice U/Sec. 154 on 22.05.2018, to which…
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Assessee is a partnership firm engaged in the business of developing of housing project eligible for deduction u/s 80IB(10) of the Act. They have developed the project which is commenced as per Commencement Certificate received in April,2007 and the project is completed as per completion certificate dated 31.03.2012. In the A.Y 2013-14, assessee earned net profit of Rs. 2.5 crores. As per the advice of the Tax Consultant, assessee firm has paid the AMT u/s 115JC on this profit as same is eligible for deduction u/s 80IB(10) of the Act. However, while uploading the return could not upload Form 10CCB…
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Client Assessment was completed under 143(3) and appeal was filed and later opted for Vivad se vishwas scheme. Taxes paid. Now PCIT issues SCN under section 263 for reopening of Assessment for the same issue higher quantum. Is it permitted?
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sir, During assessment proceedings , consequent to revision u/s 263 , the range additional commissioner of income tax has issued directions u/s 144A of the Act, whether the addl commisioner action in issuing directions to the concerned assessing officer is valid in law , he issued letter to the assesse for hearing. further , the additional commissioner of income tax issued letters to the partners of the assessee for hearing . pl guide me and any relevant case law
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Assessee is partnership firm engaged in the business of construction and development of housing project. Assessee firm has filed the Return of Income for AY 2018-19, 2019-20 and 2020-21. While filling the Return of Income as per advice of CA, added back the difference in stamp duty valuation and actual consideration u/sec 43CA of the Act. While making this disallowance, assessee firm has added the difference even though the same is less than 10%. Since the disallowance was huge, assessee firm has uploaded the Return with out making payment of self assessment tax. All the returns are processed u/143(1A) of…
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once order is passed u/s 153A/C , can it be revised by PCIT u/s 263 ?
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Assessee's assessment order u/s 147 was subject to 263 proceedings . Subsequently search took place in assessee group company and assessment u/s 153A concluded without any adverse inference touching upon the issues which were subject matter of earlier 263 proceedings , although the AO was unaware of any such 263 proceedings. The assessment u/s 153A had attained finality & no 263 proceedings initiated by Department against such order . The earlier 263 order was challenged before ITAT which set aside the matter back to CIT for giving opportunity. Despite the CIT informed about subsequent 153A order which has merged &…
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263 Revision