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The case examined whether an appeal dismissed as withdrawn under the Vivad Se Vishwas Scheme could survive when tax payment was uncertain.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.
Holding that actions prescribed by statute must be performed only in the specified manner, the Tribunal deleted the penalty. The case reinforces the importance of lawful service of notices before penal action.
The issue was whether a housing society could intervene in insolvency proceedings. The Court held that societies are distinct juristic entities and lack standing unless recognised as creditors or authorised representatives. The ruling clarifies strict limits on participation at the pre-admission stage.
Additions were deleted after finding that the Revenue relied on presumptions rather than tangible proof. The decision reinforces that the burden to prove undisclosed income lies on the tax authorities.
The case examined whether full purchase disallowance was justified without rejecting books of account. The Tribunal held that in such circumstances, only a reasonable profit element could be added.
Although the assessee quoted the wrong provision in the appeal form, the challenge was clearly against a scrutiny assessment. The Tribunal ruled that procedural lapses cannot defeat a valid statutory appeal.
