Revenue failed to produce a Section 153C satisfaction note showing the date of handing over seized material. ITAT treated the notice date as the deemed search date and held AY 2012-13 beyond jurisdiction.
The issue was whether an assessment could survive when statutory notices were issued in the name of a deceased person. The Tribunal held such notices invalid and quashed the entire assessment.
The case involved share capital raised at a high premium based on unexecuted projects and circular fund routing. ITAT held that failure to prove creditworthiness and genuineness justified addition under Section 68.
The Tribunal considered whether a penalty can stand independently while the core addition is pending fresh adjudication. It ruled that penalty cannot precede final determination of income and must be deleted at this stage.
The Tribunal examined whether the AO formed an independent belief before reopening. Finding verbatim reasons and rubber-stamp approval, it set aside the reassessment and consequential penalty.
The Tribunal assessed compliance with revised reassessment provisions post Finance Act, 2021. It ruled that sanction by a lower authority after three years is non-est in law, leading to quashing of the reassessment.
Statements recorded under Section 161 Cr.P.C. were held insufficient without corroborative evidence. The Board stressed admissibility and evidentiary standards. The ruling protects professionals from weak evidentiary claims.
CIT(A) remanded a completed scrutiny assessment even after the AO accepted additional evidence in remand. ITAT ruled this exceeded statutory powers and restored the case to CIT(A) for a merits-based decision.
The issue was whether an assessment could survive when the scrutiny notice was not issued in the CBDT-prescribed e-format. The Tribunal held the notice invalid and quashed the entire assessment as void.
The issue was whether screen-based stock exchange trades can be ignored due to alleged exit providers. The Tribunal ruled that non-response of buyers and weak financials of counterparties do not invalidate genuine exchange-routed transactions.
