The Court held that when multiple authorities are required to communicate an EC, the appeal limitation period begins from the earliest communication. Subsequent notifications cannot extend the period, emphasizing timely action by aggrieved parties.
The Tribunal upheld the CIT(A)’s findings after noting the assessee produced no evidence to counter verified disallowances. Key takeaway: appellate relief requires substantiated rebuttal of factual verification.
The Tribunal removed the interest disallowance after holding that the assessee’s earlier favourable ruling covered the issue. Key takeaway: once a factual issue is already adjudicated in the assessee’s own case, consistency must be maintained.
The ITAT sent back the issue of carry-forward business losses for re-examination because assessment records did not clarify earlier allowances. Key takeaway: loss set-off must be verified year-by-year before denial.
The case examines whether a Section 148 notice issued after the extended limitation period was invalid. Key takeaway: approval beyond three years required the higher authority under Section 151(ii), making the notice vulnerable.
The capital-gains addition of ₹4.02 crore arose from 143(1) but was included in the 143(3) scrutiny assessment. ITAT directed CIT(A) to decide the appeal on merits, ensuring the assessee’s rights during scrutiny are protected.
The Tribunal held that the CIT(A) erred by dismissing the penalty appeal solely due to VSVS settlement of interest, without adjudicating the depreciation-related penalty. Key takeaway: all grounds must be decided on merits even when only part of the quantum is settled.
The AO changed the charge from bogus payments to 69A ‘Unaccounted Sales’ without issuing a fresh notice, denying the assessee a proper hearing. ITAT remanded the matter for verification of documentary evidence including invoices, GST returns, and e-way bills.
The ITAT Mumbai deleted Rs. 10.84 crore addition made under Section 68, ruling that the assessee had properly documented loans and repayments. Key takeaway: Genuineness of transactions with third-party entities can neutralize claims of unexplained credits.
The Tribunal held that several comparables selected by the tax authorities failed the RPT filter and were functionally dissimilar, warranting exclusion. It ordered verification, directed inclusion of suitable event-management comparables, and remanded the interest-on-receivables and ICDS issues for fresh review.
