ITAT held that a penalty under Section 271(1)(c) is invalid when concealment and inaccurate particulars are invoked together without specifying the exact charge. The ruling reinforces that penalty notices must be unambiguous and legally precise.
ITAT held that Section 263 requires the PCIT to conduct independent inquiry before declaring an order erroneous. Since the PCIT relied only on assumptions of inadequate inquiry, the revision was invalid.
The Tribunal held that although transportation proof was lacking and the supplier was unverifiable, accepted sales established that trading had occurred. It ruled that only the profit element of 2% could be added, and the addition could not be taxed under section 115BBE.
The Tribunal ruled that unexplained investment cannot be added without confronting the assessee with the Koinex transaction data relied upon by the AO. Matter remanded for fresh verification.
Holds that once a tax dispute is settled under the Vivad Se Vishwas Act, Section 263 revision cannot be invoked. Confirms that VSV grants finality and bars reopening of settled issues.
Tribunal holds that Section 28 interest forms part of compensation for compulsory acquisition and cannot be taxed as income from other sources. Confirms exemption under Section 10(37).
ITAT holds that ignoring a valid online reply and supporting records vitiates reassessment; AO must first verify whether deposits were already in books before taxing. Key takeaway: non-consideration of evidence makes additions unsustainable.
Tribunal holds that the CBDT circular exempting commercial transactions was wrongly ignored; AO must re-verify if the shareholder loan was a genuine business accommodation before taxing under Section 2(22)(e).
ITAT ruled that organising Kathas or Yagnas for charitable fundraising does not constitute a religious object under Section 80G. The trust’s dominant objects were charitable, and expenditure on religious events was minimal. Approval under 80G(5) was therefore directed by the Tribunal.
The ITAT held that notices under Section 148 issued by JAO post-29.03.2022 lacked jurisdiction. Consequently, the reassessment was annulled, emphasizing only Faceless Assessing Officers can issue such notices.
