ITAT Delhi ruled that expiry of limitation only bars recovery and does not extinguish the debt itself. Outstanding loans remain liabilities unless expressly waived by lenders.
The Tribunal ruled that the Assessing Officer could issue a reassessment notice only within the balance days available after excluding the stayed period. Issuance beyond that surviving window renders the notice time-barred.
ITAT Delhi ruled that granting a common approval for several assessment years violates statutory safeguards. Search assessments collapse if approval is mechanical or omnibus in nature.
The Tribunal ruled that registration cannot be cancelled for non-maintenance of separate books when that allegation was never put to the assessee. Authorities must specify the exact clause of specified violation relied upon.
The Tribunal found that the AO had examined land records, crop sale documents, and other evidence before making the assessment. Since due inquiry was conducted, the assessment order was neither erroneous nor prejudicial to revenue.
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.
