The Tribunal found merit in the respondent’s argument that ITC comparison should be based on identical goods and services and directed DGAP to re-investigate.
The Court observed that show cause notices had clearly provided opportunities for personal hearing and submission of documents. It directed payment of costs after finding the allegation of denial of natural justice to be false.
Rules 262–265 of the Draft Income-tax Rules 2026 prescribe the procedure for issuing a charge-sheet, conducting inquiries, and passing disciplinary orders against income-tax practitioners accused of misconduct.
Rules 258–261 of the Draft Income-tax Rules 2026 lay down provisions for cancellation of registration certificates, removal of practitioners from the register, and mandatory inquiry before disqualification.
The Tribunal held that an amount paid under protest before adjudication cannot be treated as duty under the Central Excise Act. It ruled that interest at 12% per annum must be paid from the date of deposit until refund.
The Tribunal allowed the bank’s recovery application after borrowers failed to appear or dispute the claim, resulting in an ex-parte decision. It permitted recovery of ₹37.80 lakh with interest and costs and allowed sale of hypothecated assets if payment is not made.
Draft Rules 254–257 establish procedures for authorised representation, registration, and certification of income-tax practitioners under Section 515 of the Income-tax Act.
The Tribunal ruled that simultaneous proceedings arising from reassessment and revision for the same year could lead to multiplicity of proceedings and inconsistent findings. It restored the entire matter to the Assessing Officer for consolidated de-novo adjudication.
Draft Rules 252 and 253 specify the educational qualifications required for authorised income-tax practitioners and define “business relationship” to avoid conflicts of interest.
Draft Rules 250 and 251 of the Income-tax Rules 2026 define key terms related to income-tax practitioners and recognise specific accountancy examinations for eligibility under Section 515.
