The assessment was quashed because the mandatory notice under section 143(2) was issued by an officer lacking jurisdiction. The ruling confirms that jurisdiction must exist at the notice stage itself.
The Tribunal ruled that AMP expenses incurred by a brand-owning trader cannot be allocated to contract manufacturers without proof of obligation or agreement. Tax incentives enjoyed by related entities alone were held insufficient.
ITAT held that dismissing a ground without reasons violates appellate duty. The 43B disallowance was remanded for fresh, reasoned adjudication.
The Tribunal held that profit estimation cannot rest on conjectures or lump-sum allegations. In absence of identified bogus purchases or factual basis, the entire addition was deleted.
Delhi ITAT held that a purchase-return mismatch does not constitute misreporting under section 270A(9). Immunity under section 270AA was granted, quashing the ₹10.69 lakh penalty.
The Tribunal ruled that non-compliance with the faceless reassessment scheme strikes at jurisdiction itself. JAO-issued notices post-notification were held legally unsustainable.
The Tribunal ruled that the appellate authority erred by admitting new documents without a Rule 46A application or giving the Assessing Officer a chance to rebut them.
The issue was whether reassessment and appellate orders could stand when participation was ineffective and grounds remained undecided. The Tribunal ruled that justice required restoration of the case to the Assessing Officer.
The issue was whether CBDT monetary limits barred the revenue appeal. The Court held that organised tax evasion and accommodation entry cases are carved out exceptions, defeating the low tax effect argument.
The dispute involved taxing a foreign investment as unexplained income. The Tribunal clarified that Section 69 applies only where investments are not recorded in books or the source remains unexplained.
