The ITAT Delhi held that an omnibus satisfaction note without identifying year-wise incriminating material or its relevance to the assessee’s income cannot sustain proceedings under Section 153C. The assessments were consequently quashed without examining the merits of the additions.
The Calcutta High Court held that Section 115JB was not applicable to Assessment Year 2011-12 as it became effective only from Assessment Year 2013-14. The appeal was dismissed in favour of the assessee.
The ITAT Delhi held that dumpers used in manufacturing and mining operations are part of plant and machinery and qualify for additional depreciation under Section 32(1)(iia). It ruled that actual use, and not merely road-going capability, determines eligibility.
ITAT Delhi held that a reassessment initiated by an Assessing Officer without pecuniary jurisdiction under CBDT Instruction No. 1/2011 is invalid. The Tribunal quashed the reassessment and dismissed the Revenues appeal.
The ITAT held that reassessment was invalid because the Assessing Officer did not dispose of the assessee’s objections through a separate speaking order before completing reassessment. The Tribunal quashed the reassessment following the principles laid down in GKN Driveshafts.
The Delhi High Court held that an assessment order continues to exist even if an interim court order prevents it from being given effect to. It permitted the petitioner to file a fresh application under the Direct Tax Vivad se Vishwas Scheme, 2024.
The Gujarat High Court held that reassessment under Section 148 cannot be based on third-party loose papers that fail to establish a live link with the assessee. The Court quashed the notice as the material was vague and unrelated to the petitioner’s transaction.
The Gujarat High Court set aside the reassessment proceedings after holding that they were founded on an undated and uninvestigated complaint without any direct link to the petitioner. The Court found the reopening to be based on conjectures and surmises.
The Calcutta High Court held that sales tax remission under the West Bengal Incentive Scheme, 1993 was a capital receipt as it was intended to encourage capital investment and industrial expansion. It also decided the Section 80IA/80HHC issue in favour of the assessee.
The dispute concerned deduction of CSR expenditure incurred before Explanation 2 to section 37(1) became applicable. The ITAT held that the contribution, made under Ministry of Shipping guidelines, was allowable for AY 2012-13. The decision emphasised that the statutory bar introduced from AY 2015-16 could not be applied retrospectively.
