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5 साल के लिए मैनेजमेंट कंट्रोल ड्रिलिंग रिंग का लेने की फीस कैपिटल एक्सपेंडिचर है और उस पर डिप्रेशन लेने का अधिकार है
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No addition in respect of share application money when names and addresses of share holders were given to AO
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When Assessee was able to prove all three components of identity, genuineness and creditworthiness of share application/premium amount received by it, same could not be added to assesse’s income as ‘Unexplained cash credits’ u/s 68
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Notice 143(2) to issue in time else assessment cancelled
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document found during the course of search
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Friends, it has been held that Once Settlement Commission has completed proceedings, its order has to be considered conclusive as regards matters “stated therein” per Section 245I and reopening any proceeding in respect of matters covered in order would be barred. Any reassessment proceedings sought to be excluded from purview of “case” must be in respect of Section 148 notice sent while proceedings before Settlement Commission are ongoing. Once Settlement Commission had completed proceedings, its order had to be considered conclusive as regards matters “stated therein” per Section 245I and reopening any proceeding in respect of matters covered in order would be barred. Therefore, impugned notice issued to assessee u/s. 153C could not be sustained. Hence, impugned notice and all further proceedings quashed. It was open to the respondent/Revenue to move the Settlement Commission for appropriate relief of declaration that its previous order under Section 245D (6) is void, setting out the relevant facts and circumstances. Assessee’s petition allowed
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If sufficient withdrawals is proved then source of investment is proved
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When any document or details was filed by assessee in pursuance to direction of CIT(A) then there would be no violation of Rule 46A.
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Recording of satisfaction is sine qua non for initiating proceedings u/s. 153C .
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In case of completed assessment, assessment under section 153A only on the basis of the recovery of incriminating material found during the course of search