The tribunal held that reopening of assessment was invalid due to invocation of the wrong Explanation under Section 147 despite a completed assessment under Section 143(3).
The issue was whether delay of 18 months could be rejected without proper opportunity. The ITAT held that fair hearing is essential and remanded the matter for reconsideration of delay with supporting evidence.
The issue was whether the assessment order could be revised for lack of inquiry. The Tribunal held that since the Assessing Officer had examined the issues and taken a view, revision under Section 263 was not justified.
The Court examined whether a single notice covering multiple years was valid. It held that differing limitation periods make such notices prejudicial and upheld separate adjudication.
The Court examined whether additions based on a seized document were valid. It held that lack of investigation and inconsistencies rendered the additions unsustainable.
The issue was whether delay in filing appeal without strong documentary proof should be condoned. The ITAT held that when sufficient cause exists, delay must be liberally condoned to ensure justice and hearing on merits.
The issue was whether authorities could refuse symbol allotment without legal grounds. The Court ruled that absence of prohibition required fair consideration and granted relief.
The Tribunal examined whether foreign assignment salary credited in India is taxable. It held that salary for services rendered outside India is not taxable, even if received in India.
The Tribunal examined whether VRS compensation could be restricted under section 10(10B). It held that the scheme was effectively retrenchment, allowing full exemption and deleting the addition.
The issue was whether protective additions can survive when substantive additions are deleted. The ITAT held that once the substantive addition fails on merits, the protective addition based on the same material cannot be sustained.
