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.
The Delhi High Court held that a withholding tax certificate cannot stand once the ITAT sets aside the finding of a dependent agent PE. Since the Revenue relied solely on quashed assessment orders, the 8.75% TDS was invalid.
The Delhi High Court held that expiry of 120 days under Section 132B does not trigger automatic release of seized assets. The only consequence of delay is interest liability, reaffirming that AO’s satisfaction is essential.
The Tribunal held that approval by an incompetent authority under Section 151(ii) invalidates a reassessment issued after three years. The notice and consequential order were declared void for lack of jurisdiction.
ITAT ruled that deductions under section 80P cannot be disallowed at the CPC stage for returns filed after the due date prior to Finance Act 2021. The matter was remanded for proper verification by the AO.
ITAT ruled that enhancement of income under section 251 without giving the assessee a proper hearing is invalid. The appeals were remanded to CIT(A) for fresh adjudication.
