The Tribunal held that reassessment beyond three years is invalid where the alleged escaped income is below ₹50 lakh. A notice issued for a ₹5 lakh donation was declared void ab initio.
The Tribunal held that reopening based solely on Insight Portal inputs without independent application of mind is invalid. Since the reassessment itself failed, the addition of share LTCG as unexplained income under section 68 could not survive.
The Tribunal held that estimating business income at 10% of turnover without citing comparable cases or industry benchmarks is unsustainable. Arbitrary profit estimation must be supported by material evidence.
Taxing a debenture waiver as revenue income was challenged. The Tribunal rejected the approach, holding the waiver arose from capital financing and not trading operations. The ruling confirms that capital restructuring gains are not taxable by default.
The Tribunal found that full construction cost was not proved with evidence. However, a reasonable ad-hoc allowance was granted considering practical difficulties.
The Tribunal held that reassessment cannot survive when no addition is made on the very issue for which reopening was initiated. Once the recorded reason fails, the entire reassessment collapses.
The case examined whether an appeal dismissed as withdrawn under the Vivad Se Vishwas Scheme could survive when tax payment was uncertain. The Tribunal ruled that actual payment must be verified and remanded the matter for fresh examination.
The addition under Section 69 was remanded as the assessee claimed the source through rotation of funds. The Assessing Officer must now verify the fund flow after granting proper hearing.
The Tribunal held that reassessment notices issued after 01.04.2021 for AY 2015-16 are time-barred. Such reopening is invalid despite reliance on TOLA, and must be quashed.
The Tribunal held that late filing of Form 10CCB is a procedural lapse. Deduction cannot be denied when the audit report is filed before assessment processing.
