The ruling clarifies that unauthenticated digital chats and screenshots cannot form the sole basis of tax additions without proper verification and legal compliance.
The court held reassessment invalid where proceedings were based solely on unverified digital material from unrelated parties. It ruled that absence of a live nexus with income escapement makes reopening unsustainable.
The Tribunal rejected the Revenue’s argument that taxpayers must seek AO determination under Section 195(2) in all cases. It held that such obligation arises only when income is chargeable to tax in India. This ruling reduces procedural burden where taxability itself is absent.
The Tribunal held that additions based on presumptions without evidence cannot be sustained fully. It reduced the addition on unexplained cash deposits from 10% to 5%, granting relief to the assessee.
ITAT held that a return filed under section 148 remains valid even if delayed. Failure to issue mandatory notice under section 143(2) makes reassessment void.
The tribunal ruled that business income under section 44AD cannot be taxed using section 44ADA provisions. Presumptive schemes must be applied strictly as per law.
The tribunal held that the 10% safe harbour applies even to DVO valuations, not just stamp duty values. Minor valuation differences cannot trigger tax additions under section 56(2)(x).
The Court ruled that the reassessment notice was invalid as it exceeded the statutory 10-year limit under Section 153A. It clarified that the search year must be included in computing the extended limitation period.
The Court held that reassessment proceedings are invalid if approval is obtained from an incorrect authority. It clarified that sanction must strictly comply with Section 151 based on elapsed time limits. The ruling reinforces jurisdictional safeguards in reassessment cases.
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.
