ITAT held that reassessment notices issued after the surviving period, as clarified by Rajeev Bansal, are time-barred for AY 2015-16. The ruling emphasizes that procedural compliance with limitation periods is mandatory, even if notices are issued under unamended law.
ITAT Delhi held that a single Section 153D approval for multiple assessees and years is impermissible, rendering all 153A and 153C assessments void ab initio.
ITAT Delhi allowed travelling and visa expenses paid by assessee’s sons as wholly & exclusively for business purposes in overseas education consultancy. The Tribunal emphasized that procedural delay of 5 days should not defeat substantive justice, partly allowing the appeal.
ITAT Kolkata condoned an extraordinary delay in filing appeals, emphasizing that genuine and unavoidable reasons justify late filing, allowing the appeals to proceed for adjudication.
ITAT ruled that a Section 50C addition cannot stand without a DVO reference where market value is disputed. Matter remanded for fresh valuation and reconsideration.
The Tribunal held that Section 69 additions based solely on pen-drive data and an employee’s statement from a third-party search could not be sustained. No corroboration or confrontation to the assessee was provided. The ruling confirms that unsupported electronic data cannot create taxable on-money additions.
The Tribunal held that conflicting judicial views on Section 10(38) exemption made the issue debatable. Since the assessee disclosed all facts, penalty for concealment could not survive despite later denial of exemption.
The Tribunal quashed additions for bogus purchases, cash seizures, and transfer pricing adjustments, affirming the AOP’s unified management and correct taxation at the consortium level.
ITAT Delhi restored the matter to AO, allowing the assessee to submit evidence on share and agricultural status of land to correctly determine capital gains.
The Tribunal emphasized that for notices issued before 01.04.2021, the sanctioning power rested solely with the JCIT, making the PCIT’s approval invalid. Consequently, the ₹82.89 crore disallowance and all further proceedings were set aside.
