Rectification petition filed beyond the time limit set out in s. 254(2) is liable to be dismissed being time barred.
Assumption of revisional jurisdiction by CIT u/s 263 without pointing out exact error committed by AO and directed AO to make detailed and roving enquires is unsustainable in law.
CBDT extends due date for filing of report in respect of International group of subsidiaries of USA residents
Beneficial Judgement- Deemed dividend could only have been assessed in the hands of a person who was shareholder of lender company
Reassessment notice held bad in law as it was sanctioned by CIT on ground which was different from the ground of AO
Beware : Once the cash was deposited into bank account of assessee, primary onus was on assessee to prove how the said cash was sourced to avoid as unexplained amount
![[2019] 104 taxmann.com 59 (Bombay) IT : Once Commissioner (Appeals) had passed order after verification of merit of claim of expenditure and depreciation, Tribunal was not right in law in reversing said conclusion without examining its correctness Section 254 of the Income-tax Act, 1961 - Appellate Tribunal - Orders of (Non-speaking orders) - Assessment year 2006-07 - Assessing Officer passed an order of reassessment, in which, additions were made by disallowing assessee-company's claim of expenditure as well as claim of depreciation - On appeal, Commissioner (Appeals) allowed both claims after verifying merit of claims - Commissioner (Appeals) found that in another year in assessee's own case Tribunal allowed depreciation on ground that assets were ready to use though assessee could not commence commercial production due to lack of working capital - Commissioner (Appeals) also found that Assessing Officer had changed its opinion from earlier Assessing Officer and disallowed impugned amounts - Whether Tribunal was not right in law in merely reversing order of Commissioner (Appeals) without any discussion or even any conclusion justifying of additions made by Assessing Officer - Held, yes Shirpur Gold Refinery Ltd.](https://thetaxtalk.com/wp-content/uploads/2019/04/Untitled-1048-min.png)
