The Tribunal held that a penalty cannot survive when the quantum addition has been deleted. Once the foundation fails, penalty under Section 271(1)(c) must also fall.
The Tribunal ruled that a draft assessment order is the statutory trigger for DRP proceedings. Absence of a valid draft order against an existing entity vitiates the entire assessment.
The Tribunal held that an appeal cannot be dismissed on the assumption of earlier adjudication without evidence. The matter was remanded for fresh decision on merits.
The Tribunal held that no interest disallowance can be made when ample interest-free funds are available. The key takeaway is that diversion cannot be presumed without establishing a nexus with borrowed funds.
The Tribunal considered whether disallowance under section 14A was justified merely because exempt income was earned. It ruled that without corresponding investments in the assessee’s books, section 14A cannot be invoked.
The Tribunal held that issuing a Section 143(2) notice is compulsory once a return is filed under Section 148. Absence of such notice vitiates jurisdiction and nullifies the reassessment.
The ruling clarified that the Finance Act, 2021 amendment applies only from AY 2022–23. For earlier years, exemption cannot be denied by treating the amendment as retrospective.
The ITAT held that reassessment proceedings remain valid even if no separate addition is made on the original reopening issue. The key lesson is that voluntary disclosure by the assessee satisfies the reopening requirement.
Rejecting the revenue’s digital-era argument, the Tribunal held that taxpayers need reasonable time to compile records. The matter was sent back for fresh assessment.
The Tribunal held that only unreconciled Form 26AS entries could be taxed while verified reimbursements deserved relief. It also ruled that godown rent already netted in business income could not be taxed again.
