The assessment based on a second notice issued in July 2022 was quashed as time-barred. Once limitation had expired, subsequent notices could not revive reassessment jurisdiction.
The ITAT ruled that customer discounts are deductible when quantified and finalised in the year of claim, even if labelled as prior-period items. The decision reinforces that timing of crystallisation outweighs book classification.
The Tribunal examined whether purchases could be treated as bogus solely on investigation inputs. It held that without independent verification or rebuttal of documentary evidence, the addition could not survive.
The tribunal held that advances received from customers for future services cannot be treated as unexplained cash credits. Once the assessee proves identity, nature, and business purpose, Section 68 addition fails.
The tribunal held that prior approval under Section 153D was granted mechanically without application of mind. Such invalid sanction vitiated the entire search assessment, leading to quashing of the order.
The tribunal held that salary payments, even with TDS and bank transfers, require proof of genuineness and business nexus. The matter was remanded to the Assessing Officer for fresh verification of employee evidence.
The Tribunal recognised that funds could not be used due to a High Court injunction. Such legally restrained non-utilisation cannot be treated as a statutory violation.
The Tribunal ruled that inventory figures from a management Excel sheet, without quantity details or physical verification, cannot form the basis of an addition. Properly recorded GST-compliant sales explained the variance.
The Revenue argued AMP functions required separate compensation under DEMPE principles. The Tribunal rejected this, holding that consistent past rulings prevail absent material factual change.
Holding that justice requires a reasoned order after hearing both sides, the Tribunal remanded the appeals. Continued non-cooperation may still permit ex parte disposal.
