The Tribunal held that Section 263 cannot be invoked when the PCIT himself does not conduct the verification he insists was missing. It reaffirms that revision requires demonstrated lack of inquiry, not assumptions.
The ITAT held that without a condonation petition, a 300-day delay cannot be excused. The ruling underscores that delay must be justified before merits—including Section 80P—can be considered.
The Tribunal allowed withdrawal after noting that the case was already remanded under section 251(1)(a). The once a matter is reopened before the AO, the assessee may abandon the pending appeal.
The Tribunal held that the assessee cannot suffer due to the AO’s inaction under section 270AA(4), directing grant of immunity and cancelling the 270A penalty.
ITAT confirmed that External Development Charges paid to HUDA constitute payment for work, making TDS deduction mandatory and sustaining the demand under sections 201(1) and 201(1A).
The Delhi ITAT held that reopening an assessment based solely on audit objections, without fresh material, is invalid. The tribunal emphasized that reassessment cannot be used for a mere change of opinion
ITAT held that delay must be assessed from the date of service, condoned a 474-day delay, and directed the CIT(A) to reconsider the 42-day delay on merits.
The ITAT held that crucial documents unavailable earlier must be considered, admitting them under Rule 29 and sending the ₹2.38 crore addition back for fresh examination.
The ITAT ruled that failure to issue a mandatory Section 143(2) notice and disregarding an e-verified return rendered the reassessment void. The addition of ₹50.50 lakh was deleted.
ITAT Delhi remanded the case to verify whether imports made using a firm’s PAN were recorded in the company’s books. CIT(A) deletion was quashed as factual examination was needed.
