The Tribunal ruled that additions based on third-party search without giving the assessee a chance to examine evidence violated natural justice, deleting ₹2.04 Cr and ₹64.11 Lakh for AY 2018-19 & 2019-20.
The Tribunal held that the assessee’s delayed filing was bona fide due to disputes and legal ambiguities, and the declared income was fully accepted. No penalty under Section 270A was warranted.
Tribunal ruled that a 148 notice issued on 03.04.2022 for AY 2015-16 violated Section 149(1)(b)’s six-year limitation, rendering entire reassessment void. The is that notices issued after 31.03.2022 for AY 2015-16 are invalid.
ITAT confirmed Section 263 revision after finding that the AO wrongly allowed delayed PF/ESI contributions despite binding Supreme Court law. The reassessment was deemed erroneous and prejudicial to Revenue.
The ITAT held that reassessment notices under section 148 issued to a deceased person are invalid, emphasizing that such notices cannot confer jurisdiction and proceedings are void ab initio.
The ITAT Hyderabad ruled that unexplained partner capital contributions cannot be treated as income of the firm. Only individual partners’ contributions can be assessed, overturning a Rs. 3.26 crore addition.
