ITAT Delhi held that mere Whatsapp messages showing demand do not justify Section 69A additions unless actual receipt of money is proved.
The issue was whether CPC could disallow share capital fees not claimed as deduction. The ITAT held that no adjustment is permissible when the amount is directly booked in retained earnings.
The Tribunal held that ritualistic approval under section 153D, without application of mind, vitiates search assessments. Mandatory supervisory approval must reflect genuine examination of draft orders.
The ITAT held that appeals must be filed before the correct jurisdictional bench. An appeal filed before the wrong Tribunal is liable to dismissal at the threshold.
The ITAT held that approval under section 151 by an incompetent authority invalidates reassessment. Sanction must strictly follow statutory hierarchy.
The Tribunal upheld revision after finding that the Assessing Officer accepted explanations without proper verification. The ruling stresses that insufficient enquiry can justify action under Section 263.
The ITAT held that denying registration without adequate opportunity is invalid. Authorities must fairly examine replies and documents before rejection.
The dispute concerned computation of capital gains on sale of shares affected by corporate actions. The Tribunal affirmed that detailed tranche-wise analysis and statutory indexation justified allowance of long-term capital loss.
The Tribunal held that a transfer pricing order passed beyond statutory limitation is non est in law. As a result, the assessee ceased to be an eligible assessee under section 144C, making the final assessment beyond limitation and void.
The Tribunal deleted a penalty imposed for alleged non-maintenance of accounts. It held that audited books, even if defective, do not attract penalty under Section 271A.
