“Section 270(3)”
The decision most relied on for Section 270(3) is Andhra Pradesh in CIT v. Smt. Nayana P. Dedhia (270 ITR 572), cited in 82 judgments on BharatTax.
Leading authorities on Section 270(3)
Guidelines issued by the Central Board of Direct Taxes (CBDT) under Section 119 of the Income Tax Act, which relax the rigour of law, are binding on all income tax officers responsible for implementing the Act, who must follow these orders and instructions.
No separate disallowance under Section 40A(3) is required when income is estimated by adopting a Net Profit Rate.
The assessee's past years' declared profits are the best guide for applying Gross Profit (GP) or Net Profit (NP) rates. Deviating from this history requires justification and consideration of comparable cases only when necessary.
An inaccurate claim made by the assessee cannot be treated as a case of giving inaccurate particulars of income for the purpose of imposing penalty.
Reassessment beyond four years after an assessment under Section 143(3) is not permissible unless the Assessing Officer specifies the assessee's failure to disclose all material facts.
