ITAT Chennai set aside the appellate order and remanded issues on protective addition, Section 54F exemption, and TDS credit mismatch for fresh adjudication.
The Tribunal held that loans received from NBFCs cannot be treated as unexplained where identity, creditworthiness, and genuineness are established. Absence of incriminating material led to deletion of additions.
The issue involved additions based on mismatch between property registration and payment dates. The Tribunal held that delayed encashment of cheques does not indicate unexplained investment. It concluded that the additions lacked factual basis and directed deletion.
The Court stayed reassessment proceedings after constitutional issues were raised. The key takeaway is interim protection when arguable legal questions exist.
The court set aside a GST demand order citing violation of natural justice as no hearing opportunity was given. However, relief was conditional on full deposit due to delay in approaching the court.
The ruling emphasizes that once the Transfer Pricing Officer accepts the arm’s length nature of a transaction, the Assessing Officer cannot question its reasonableness. The disallowance was deleted as the interest rate complied with transfer pricing norms and reflected commercial reality.
The Court refused to quash criminal proceedings, holding that disputed facts cannot be decided in Section 482 jurisdiction. It allowed the applicant to seek discharge before the trial court.
The case examines whether revision under Section 263 was validly exercised. The Supreme Court upheld the High Court ruling that lack of independent application of mind invalidated the revision, reinforcing limits on PCIT powers.
The case examined whether revision under Section 263 was validly invoked. The High Court held that reliance on the Assessing Officer’s reference without independent application of mind invalidated the revision.
The case involved long-pending criminal proceedings where co-accused were acquitted due to lack of evidence. The Supreme Court indicated that excessive delay alone may justify quashing and stayed further trial proceedings.
