The Court held that reassessment based solely on an audit objection is invalid as it constitutes a change of opinion. It emphasized that previously examined issues cannot be reopened without new tangible material. The ruling reinforces limits on reassessment powers.
ITAT confirmed that the amended 60% tax rate under Section 115BBE applies prospectively from April 2017 onwards. For earlier transactions, only the 30% rate applies, safeguarding taxpayers from retrospective burden.
ITAT ruled that the amendment requiring aggregation of consideration under Section 194-IA applies only from October 2024. For earlier years, TDS applicability must be determined individually per buyer-seller transaction.
The issue was whether LIC premium payments for post-retirement annuity were contingent liabilities. The Court held they represented an existing liability and allowed the deduction as a business expense.
The case examined the validity of reassessment notices issued beyond the permissible period. The Court ruled that such notices are invalid in light of binding precedent, leading to quashing of the entire reassessment.
The issue was whether rejection of books and GP estimation was justified due to missing records. ITAT upheld the addition, ruling that failure to produce bills, vouchers, and stock records justified estimation.
The issue was whether repayment of loans through banking channels proves genuineness under Section 68. ITAT Delhi held it does not, ruling that bogus loans remain unexplained even if repaid.
The issue was whether a single satisfaction note for multiple years is valid under Section 153C. ITAT Pune held it invalid, ruling that separate satisfaction per year is mandatory, thereby quashing the entire assessment.
The Court held that rejection of a lower withholding certificate without reasons violates Rule 28AA. It remanded the matter for fresh consideration with a speaking order.
The tribunal ruled that compensation under a government-approved restructuring scheme qualifies as retrenchment. It allowed full tax exemption under Section 10(10B).
