The Tribunal ruled that reopening based merely on audit objection without independent application of mind is unsustainable. An audit note cannot replace the Assessing Officers reasoned belief.
The order held that failure to file DIR-12 within 30 days of resignation violated Section 170(2). The key takeaway is that administrative vacancy does not excuse statutory filing delays.
The Tribunal emphasized that substantive justice prevails over technical PAN mismatch. Since income of the deceased was offered and accepted, TDS credit had to be allowed to the legal heir.
The Registrar imposed a penalty for failure to appoint the required two independent directors within the prescribed three-month period. The default continued until full compliance was achieved.
ITAT deleted the addition made under Section 153C as no incriminating material directly linked the buyer to alleged cash payments. Reliance solely on third-party pen drive data and statements was held insufficient.
The decision clarifies that the monetary threshold under Section 149 applies to actual taxable income, not purchase turnover. As the addition fell below ₹50 lakh, reassessment proceedings were invalid.
The Tribunal ruled that once the Assessing Officer scrutinized the Section 10AA claim and R&D allocation, revision cannot be invoked. Section 263 cannot be used to re-examine issues already verified during assessment.
The ruling explains that DVO reference is a procedural safeguard, while the safe harbour proviso grants substantive relief. Both provisions can be applied simultaneously where conditions are satisfied.
The Tribunal ruled that actual use of the property during the year is not a pre-condition for including it in the block of assets. Depreciation eligibility differs from eligibility for block inclusion under Section 50.
The Tribunal emphasized that without physical goods, exports and stock reconciliation would not be possible. Since quantitative records and gross profit remained consistent, the addition under Section 69C was deleted.
