The Tribunal held that search-based reassessments issued beyond six assessment years are barred by limitation. Revenue appeals were dismissed as the statutory time limits could not be extended.
Construction, fit-out, and IT installation costs capitalised in fixed assets were held genuine. The Tribunal emphasized substance of records over suspicion based on third-party allegations.
The Tribunal held that no TDS demand can survive where tax was duly deposited and PAN became operative within the CBDT-prescribed timeline. Deductors are entitled to relief under the beneficial 2024 CBDT circular.
The Tribunal held that reassessment initiated solely on the basis of an audit objection, without any independent application of mind, is invalid. Such reopening lacks the mandatory reason to believe and cannot sustain in law.
Sales already offered to tax cannot be added again under section 68. With stock movement evidenced and books not rejected, treating recorded turnover as unexplained cash credit was held unsustainable.
The Tribunal held that estimating profit at 20% of turnover in a milk trading business was arbitrary and unsupported by industry realities. It restricted the gross profit rate to 5%, recognising wastage, spoilage, and thin margins typical to the trade.
The Tribunal ruled that when purchases are disallowed as non-genuine without questioning the source of payment, section 69C cannot be invoked. A plausible disallowance under section 37(1) cannot be revised under section 263 merely to change the charging provision.
The AO treated loan substitution via group restructuring as an accommodation entry. ITAT ruled that repayment by a holding company backed by bank trails and confirmations cannot be taxed as unexplained credit.
ITAT Mumbai quashed reassessment for AY 2017-18 as notice issued after three years lacked mandatory sanction under Section 151(ii), holding approval by Pr.CIT insufficient under post-2021 law.
The Supreme Court held that the inclusion of a tainted official in the selection committee created a reasonable apprehension of bias. The key takeaway is that even one biased member vitiates the entire selection process.
