Karnataka High Court invalidated reassessment proceedings and related notices for AY 2015-16, holding that actions initiated beyond Section 151A are legally void.
The ITAT held that limitation under section 144C(13) starts from the date DRP directions are uploaded on the ITBA portal. A final order passed beyond this deadline was declared void ab initio.
The ITAT held that CPC and CIT(A) acted prematurely in denying section 80P deduction while a section 119 condonation application was awaiting decision. The matter was remanded for fresh adjudication after condonation is decided.
The issue was whether mutation could be refused solely because it was sought on the basis of a will. The Supreme Court held that such refusal was erroneous and restored mutation, clarifying that mutation is fiscal and subject to civil adjudication.
The ITAT held that approval merely stating “Yes, I am satisfied” shows no application of mind. Such sanction fails the statutory requirement and invalidates reopening.
The ITAT held that loans and advances accepted in earlier scrutiny assessments cannot be doubted later without fresh incriminating material. Mere balance-sheet analysis or suspicion is insufficient.
The ITAT held that a reassessment notice issued by the Jurisdictional AO after 29-03-2022 violated the mandatory faceless reassessment scheme. Such a jurisdictional lapse vitiates the entire proceedings.
The High Court held that granting less than seven days to reply to a show-cause notice violates mandatory SOPs. Such a breach vitiates the entire faceless assessment process.
The ITAT held that disallowance under Section 36(1)(iii) requires factual verification of business purpose. Interest-free loans to group entities were sent back for fresh examination.
The ITAT held that unrecorded sales cannot be taxed in full under Section 69A. Only the profit element at a reasonable GP rate is assessable as business income.
