The Tribunal held that the reassessment was issued 45 days beyond the maximum permissible period under Rajeev Bansal (SC), making the 148 notice invalid. Applying the deemed-notice framework of Ashish Agarwal, it ruled that the AO had “zero surviving days” to act. The reassessment was quashed for being issued after the statutory outer limit.
The Tribunal invalidated an assessment passed without awaiting the Departmental Valuation Officer report, holding that provisional assessments violate section 50C(2) and 143(3). The rectification under section 154 based on later material was also impermissible.
Reassessment notice issued beyond statutory time limit under Section 148 was invalid; Tribunal quashed proceedings for A.Y. 2013-14, emphasizing procedural compliance.
The Tribunal held that the original assessment was not erroneous or prejudicial except for TDS verification and PF/ESI disallowance. The assessee’s claim under Section 10AA was rejected. Compliance with statutory deductions is critical for valid assessments.
The Tribunal upheld CIT(A)’s order, confirming deletion of additions related to unexplained creditors, GST, bogus purchases, and purchase differences. Proper reconciliation and supporting documents established genuineness, highlighting the importance of maintaining accurate records.
Tribunal rules that Souharda societies registered under state law qualify as cooperative societies under section 2(19), allowing 80P(2)(a)(i) and 80P(2)(d) deductions. Revenue’s appeal dismissed.
ITAT Pune held that the Section 263 revision was unsustainable as the AO conducted adequate scrutiny and expenses were recovered from associated enterprises. Expenditure classification did not make the assessment prejudicial to revenue.
The Tribunal found that the Section 148 notice appeared on the portal after 31.03.2021, raising doubts about its validity. The matter was restored to CIT(A)/NFAC for fresh consideration, allowing the assessee to submit explanations. The ruling underscores strict compliance with notice issuance requirements under Section 148.
Receipt and repayment of Rs. 2.02 crore via proper banking channels establishes genuineness of the transaction; Section 68 addition was deleted despite non-materialisation of business.
The Tribunal condoned an 868-day delay arising from wrong professional advice and Covid-related extensions, holding that the assessee showed sufficient cause. It ruled that the 50C addition under Section 153A lacked incriminating material and directed a full de-novo review.
