The Tribunal ruled that statements of builder group officials, without corroborative evidence against the purchaser, cannot form the sole basis for addition. The decision reinforces the principle that third-party statements must be independently verified.
The Tribunal accepted that the taxpayer was pursuing rectification remedies and therefore condoned the delay in filing the appeal. The key takeaway is that genuine efforts to resolve disputes through alternative legal remedies can justify delay condonation.
ITAT Delhi held that reassessment under Sections 147/148 cannot be based on the same material already examined during a completed Section 153C assessment. The ruling emphasizes that fresh tangible material is necessary for valid reopening.
The Tribunal held that the satisfaction note failed to identify the documents allegedly found during the search or their connection to the taxpayer. The ruling confirms that vague references to seized material are insufficient.
The Tribunal ruled that the Delhi Assessing Officer could not legally assess the taxpayer when jurisdiction continued to remain with Mumbai authorities. The decision underscores that jurisdiction cannot shift without following statutory procedures.
The Tribunal held that the Revenue failed to establish escaped income of ₹50 lakh or more, a prerequisite for extending the assessment period beyond six years. The ruling reinforces strict compliance with statutory thresholds for extended reassessment.
ITAT Delhi held that protective additions cannot survive when the same income has already been assessed substantively in the hands of the real beneficiaries. The key takeaway is that the Revenue cannot tax identical income twice in different hands.
The Tribunal found that the Assessing Officer ignored the statutory threshold for reopening assessments beyond three years. The ruling emphasizes that reassessment notices issued contrary to limitation provisions are void in law.
ITAT found that the Assessing Officer incorrectly treated consignment transactions as the assessees turnover based solely on cess payments. The ruling emphasizes that commission agents should be taxed on commission income and not on consignors turnover.
The Tribunal held that once a Section 35D claim was accepted in earlier years, it could not be disallowed in the final amortization year without disturbing the original allowance. The disallowance of preliminary expenses was therefore delete
