#Tax Procedure

The tribunal held that a section 148 notice dated 12-April-2023 was time-barred under section 149(1)(a) because the income escaping assessment was below Rs 50 lakh, and therefore quashed the assessment disallowing the claimed deduction under 80GGC for a bogus political donation. The ruling underscores that reopening notices beyond three years are invalid when the escaped income does not exceed the Rs 50 lakh threshold.

ITAT held that the limitation clock for a Section 153C assessment begins on the date the assessing officer records the satisfaction note, not on the earlier Section 127 order. This narrows the time-bar for revenue to finalize assessments in multi-entity search cases, affecting taxpayers facing delayed notices.

ITAT Jaipur rules that failure to issue draft assessment order u/s 144C(1) for non-resident assessee renders assessment void ab initio. Key procedural compliance takeaways.

ITAT Agra rules that the Assessing Officer must record objective dissatisfaction under Section 14A(2) of the Income Tax Act before invoking Rule 8D for disallowing expenses related to exempt income like dividends. The Tribunal emphasized that mechanical application of Rule 8D without identifying expenditure relatable to exempt income is invalid, reinforcing procedural safeguards for taxpayers.