The ITAT held that a notice under Section 143(2) issued by a non-jurisdictional AO invalidates the entire assessment. Jurisdictional defects cannot be cured later, making the assessment void from inception.
The assessee could not respond to notices due to death during proceedings. ITAT ruled that bona fide non-compliance cannot override documentary evidence that fully explains the source of cash deposits.
The tribunal ruled that a penalty under section 271(1)(c) cannot stand when the quantum addition forming its basis is deleted. The key takeaway is that penalty proceedings automatically fail without a surviving assessment addition.
The issue was whether cash salary and commission payments attracted disallowance under section 40A(3). The ITAT held that since each payment was below the per-day statutory limit, the disallowance of ₹2.75 crore was unsustainable.
The issue was whether property investment could be treated as unexplained in reassessment proceedings. The ITAT held that where bank trails, NRE accounts, and loan documents fully explain the source, additions cannot survive.
The Tribunal held that a minor delay in filing Form 10B is a procedural lapse and not fatal to exemption under section 11. Substantive charitable benefits cannot be denied for trivial delays.
The Tribunal held that commission paid to a shell concern with no real services is taxable as unexplained credit. Claims that expenditure related to an earlier year were rejected.
The Tribunal remanded the case involving addition of crypto closing stock after finding procedural defects. The appellate authority must first decide limitation before examining merits.
Delhi High Court held that in cases involving multiple parties, the adjudication cannot be done by different Commissionerates, the Adjudicating Authority is fixed on the basis of the jurisdiction which has the highest amount of demand tax.
Karnataka High Court held that clubbing / consolidation / bunching/ combining of multiple tax periods/financial years in a Solitary/Single/Composite Show cause notice issued under Section 73 / 74 of the CGST / KGST Act is illegal, invalid, impermissible and without jurisdiction or authority of law.
