The Tribunal held that assessments under Section 153A cannot be sustained when no incriminating material is found at the assessees premises. Additions based on third-party material were quashed as being without jurisdiction.
The Tribunal ruled that treating a belated return as non est is legally unsustainable. Absence of a Section 143(2) notice invalidates the entire reassessment proceedings.
Payments to AwasBandhu were allowed as application of income. The Tribunal held such statutory contributions further public purposes and cannot be treated as non-business or taxable expenses.
The Tribunal held that cash advances/on-money received for an ongoing real estate project cannot be taxed before completion when the Project Completion Method is consistently followed. Income already offered and accepted in the completion year cannot be taxed again earlier.
The Tribunal examined whether a single satisfaction note could sustain reassessment proceedings for multiple years under section 153C. It held that a composite satisfaction is valid when based on common seized material spanning several assessment years.
The Tribunal held that inadvertent mistakes in filing Form 10AB cannot defeat a trust’s right to exemption. Registration was directed where objects and activities were never disputed.
The Tribunal held that a continuously maintained ledger found during search constituted reliable evidence. Additions for unexplained expenditure under section 69C were sustained based on corroborated diary entries.
The issue was whether a WhatsApp image from a third party could justify a cash addition. The Tribunal held the digital evidence inadmissible due to lack of lawful collection and chain of custody, deleting the addition.
The reassessment was annulled after the notice was found procedurally defective. The Tribunal affirmed that binding High Court precedent required issuance by a faceless AO.
The Tribunal held that once a Section 263 revision is set aside, the consequential assessment has no legal existence. All proceedings based on such assessment automatically collapse.
