The Tribunal held that section 144C cannot be invoked where the TPO proposes no income variation. As the assessee was not an eligible assessee, the assessment was quashed as without jurisdiction.
The dispute concerned denial of TDS credit citing inconsistencies in reported transaction values. The ruling clarified that Form 26AS is decisive for TDS credit when deduction and deposit are undisputed.
The Tribunal upheld deletion of additions where loan repayments were sourced from stock sales and fresh loans. It ruled that without rejecting books or disproving records, section 68 cannot be invoked.
The Tribunal considered whether RTGS credits constituted unexplained money. It ruled that once sale bills, customer ledgers, and bank entries align, Section 69A has no application.
The agreement removes or reduces duties on most traded goods. It significantly improves export competitiveness and bilateral market access.
Karnataka High Court held that jurisdiction under Article 226 read with section 482 of Cr.P.C. is exercisable only in exceptional circumstances. Thus, interim bail stands rejected since present matter cannot be termed as exceptional.
The decision reiterates that once the assessees death is known, proceedings must restart with a valid notice to the legal heir. Failure to do so makes the assessment unsustainable.
Courts have held that the two-year limit under Section 54 is not mandatory in all cases. Where the refund claim is genuine, bonafide, and causes no revenue loss, procedural delay cannot defeat substantive rights.
This case addressed whether tax appeals survive a moratorium under insolvency law. The ruling confirms that income tax proceedings stand stayed once a moratorium is imposed.
The Tribunal held that no profiteering arose where the ITC-to-cost ratio declined after GST. The key takeaway is that absence of GST-led savings defeats section 171 allegations.
