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ITAT Hyderabad remands Sunil Jayantilal Sachdev case for fresh assessment after NFAC confirmed AO’s action without considering taxpayer’s submissions.
Court emphasized that issuing a notice to a non-existent entity constitutes a jurisdictional defect, which Section 292B cannot cure.
Punjab & Haryana High Court quashes tax notices, ruling that statutory provisions take precedence over Board circulars in Anju Arora v. Union of India case.
Clause (ba) of sub-section (1) of section 12A was applicable for AY.2018-19 onwards and not for AY.2017-18, assessee-temple trust was entitled to tax exemptions under Sections 11 and 12 . Hence, the order of AO was not erroneous and prejudicial to the interests of revenue and therefore, it was not amenable to revision u/s 263.
ITAT Ahmedabad held that section 275(1A) of the Income Tax Act empowers AO to pass penalty order by enhancing or reducing penalty on the basis of assessment as revised by giving effect to orders passed by appellate authority or courts.
ITAT Ahmedabad held that the income of beneficiaries of trust cannot be treated as income in the hands of the trust. Accordingly, disallowance under section 143(1) of the Income Tax Act not justified.
The assessee had adopted Transactional Net Margin Method (TNMM) as the most appropriate method and Operating Profit/ Operating Cost [OP/OC] as the Profit Level Indicator for benchmarking the international transactions.
Delhi High Court held that AO has erroneously added value of transaction while calculating income that could possibly have escaped assessment. Accordingly, order set aside and matter remanded back to AO for fresh consideration.
The present appeal is filed by the assessee against the denial of registration under section 12AB of the Income Tax Act vide the order passed by the Commissioner of Income Tax (Exemption), Ahmedabad.
The assessee herein is a part of Allana Group, which is engaged in the business of export of food products and agro commodities including frozen meat processed/frozen food, edible products, agro products etc.
