Bunching of show cause notices did not cause any prejudice to assessee as it was open to assessee to take up any contention peculiar to any particular year in the reply to the show cause notice.
Filing of Form 10CCB required for claiming deductions under Section 80IA before the due date for filing of return of income u/s 139(1) was only directory and not mandatory for the year under consideration.
Assessee, aggrieved by the decision, appealed to the CIT (Appeals), who dismissed the appeal and upheld the decision of AO. Assessee dissatisfied with the order of CIT(A) appealed before Tribunal.
The Officers found that factory was operational. On being demanded, Sujit Kumar Bera produced all the gold available in the factory. Total quantity of gold was found to be 2417 grams.
There was no provision under the DTVSV Act that empowered a Designated Authority to reopen a concluded settlement. Once a final certificate was issued under Section 5(1), all disputes with regard to the ‘tax arrear’ stood concluded.
Assessee was justified in objecting to jurisdiction of AO and transfer of his case, which obviously could not have been adjudicated upon without affording an opportunity of hearing and disclosing to him the reasons for not accepting his point of view.
CIT(E) was not justified in denying assessee’s applications for final registration u/s 12AB / final approval u/s 80G as assessee had done only charitable activities till now and not undertaken any activity contemplated by object No. 2 & 3.
An amendment to the agreement on September 24, 2014, revised the terms of consideration. Assessee argued that possession of the property was never transferred as evidenced by ownership documents like the 7/12 extract and electricity bills.
Where assessee had produced ledger accounts, AO did not have any material to substantiate that deposits aggregating ₹66,44,134/- were made in assessee’s bank account to contradict the same.
As regarding disallowance of interest-free loans on unsecured loans, it was concluded that the same were part of routine business transactions and were of short-term nature therefore, no addition for interest charged on the loans.
