The notice under section 143(2) did not conform to the CBDT-prescribed format. ITAT ruled that a defective notice strikes at jurisdiction and invalidates the assessment.
The Tribunal held that revision under section 263 cannot introduce issues outside the original limited scrutiny mandate. The key takeaway is that the PCIT cannot widen the inquiry beyond CASS-selected parameters.
The Tribunal held that cash deposits arising from genuine sales already recorded in books cannot be taxed again as unexplained money. The key takeaway is that such additions amount to impermissible double taxation.
The dispute concerned denial of exemption due to belated filing of Form-10B. ITAT held the delay was not fatal and directed fresh consideration in light of the CBDT circular.
It was ruled that substituting sale consideration with stamp duty value during CPC processing is impermissible. Such action deprives taxpayers of the statutory right to seek DVO valuation.
It was held that sale consideration from trust property, when donated to charitable institutions, cannot be taxed as income. The ruling confirms protection for genuine charitable application of capital receipts.
The issue was whether bank credits already offered as income in an HUF’s return could again be taxed in the individual’s hands. ITAT held that double taxation is impermissible and directed the AO to verify HUF records before making any addition.
Additions were made solely because the trust failed to submit details during assessment and appeal. ITAT set aside the assessments for fresh adjudication, stressing that substantive claims should be decided on merits rather than procedural lapses.
ITAT held that Section 153C cannot be invoked where the satisfaction/hand-over date is after 01.04.2021, quashing multiple assessments framed thereafter. The ruling follows the Madras High Court and reinforces Section 153C(3)’s statutory bar.
The Court ruled that failure to substitute the legal representatives of one heir does not automatically abate proceedings. Abatement arises only where the deceased party’s interest is left wholly unrepresented.
