Upholding the appellate authority, the Tribunal confirmed that jurisdiction cannot be assumed casually against a non-searched person. Statutory satisfaction requirements are mandatory, not procedural.
The Tribunal held that notices issued under Section 148 must follow the faceless mechanism prescribed by the CBDT Scheme, 2022. Issuance by the Jurisdictional Assessing Officer instead of the Faceless Assessing Officer vitiated the proceedings.
The Supreme Court held that delay in filing execution and depositing balance sale consideration does not by itself render a decree inexecutable. Readiness and willingness, not rigid timelines, remain the decisive test.
The Court held that reassessment initiated outside the statutory framework of Section 151A is invalid. All notices and approvals issued by the jurisdictional officer were quashed, with liberty reserved for revival.
The issue was whether unsecured loans could still be treated as unexplained after repayment. The Tribunal held that once repayment is recorded by the AO, the addition is unsustainable.
The Tribunal set aside a Section 69C addition where subcontract payments were backed by bills, accounts, and TDS compliance. Non-filing of return by the recipient was held insufficient to brand the expense as bogus.
The High Court held that the Tribunal erred by not examining the respondent’s contradictory positions on ownership and remanded the matter for fresh adjudication.
The Tribunal held that leave encashment received on resignation qualifies for exemption under Section 10(10AA). Subsequent employment in the same year does not bar the relief.
Holding that procedural defects should not defeat substantive rights, the Tribunal restored the appeal. The case was remanded for reconsideration after granting opportunity.
The Tribunal held that enhancing profit to 10% without comparables was arbitrary. Past accepted margins around 6% had to guide estimation. Income was directed to be computed at 6%.
