The issue was whether mutation could be refused solely because it was sought on the basis of a will. The Supreme Court held that such refusal was erroneous and restored mutation, clarifying that mutation is fiscal and subject to civil adjudication.
The ITAT held that approval merely stating “Yes, I am satisfied” shows no application of mind. Such sanction fails the statutory requirement and invalidates reopening.
The ITAT held that loans and advances accepted in earlier scrutiny assessments cannot be doubted later without fresh incriminating material. Mere balance-sheet analysis or suspicion is insufficient.
The ITAT held that a reassessment notice issued by the Jurisdictional AO after 29-03-2022 violated the mandatory faceless reassessment scheme. Such a jurisdictional lapse vitiates the entire proceedings.
The High Court held that granting less than seven days to reply to a show-cause notice violates mandatory SOPs. Such a breach vitiates the entire faceless assessment process.
The ITAT held that disallowance under Section 36(1)(iii) requires factual verification of business purpose. Interest-free loans to group entities were sent back for fresh examination.
The ITAT held that unrecorded sales cannot be taxed in full under Section 69A. Only the profit element at a reasonable GP rate is assessable as business income.
The ITAT held that reassessment based purely on an Investigation Wing report, without the Assessing Officer forming an independent belief, is invalid. Copy-pasted reasons failed to establish a live link between material and escapement of income.
The ITAT held that Rule 8D cannot be invoked without first recording a clear dissatisfaction with the assessee’s working based on accounts. Mechanical application of the rule, without identifying specific expenditure linked to exempt income, was ruled invalid.
The ITAT held that filing Form 10B on the extended due date, especially during COVID-19 relief periods, cannot by itself defeat Section 11 exemption. Procedural delay cannot override substantive compliance.
