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Explanation 3 To Sec 147 Can t Be Resorted To Make Addition On Any Other Issue Which Is Not Included In Reasons For Reopening: New Delhi ITAT

On finding that no addition is made based on the reasons to believe recorded by the AO for reopening the assessment, the New Delhi ITAT quashed the order passed by the AO u/s 147 of the Income tax.

Non-striking on irrelevant limb u/s 271(1)(c) vitiates entire penalty proceedings

ITAT Mumbai held that as the assessee should be aware of the exact charge for which the penalty proceeding has been initiated, non-striking on the irrelevant limb under section 271(1)(c) of the Income Tax Act vitiates the entire penalty proceedings.

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