The ITAT held that a reassessment notice issued beyond the six-year limitation under Section 149 is invalid. Key takeaway: Tax authorities must strictly comply with statutory time limits.
The Tribunal found that the assessee’s audited accounts, finalized before demonetisation, clearly established sufficient cash balance to cover the ₹14 lakh deposit. Since Revenue produced no evidence of inflation or manipulation, the addition under Section 69A could not survive.
The Tribunal noted conflicting positions regarding the evidence submitted by the assessee in support of agricultural income. Since the assessment appeared incomplete and lacked thorough verification, the case was returned to the AO. The ruling directs a fair reassessment and deletion of the addition if documentary proof is found satisfactory.
The Tribunal applied long-standing rulings invalidating the intensity and BLT approaches for AMP benchmarking, deleting both substantive and protective adjustments. The decision underscores that such methods lack statutory support.
The ITAT Chandigarh ruled that a co-purchaser of property is not liable to deduct TDS under Section 194-IA if their individual share is below ₹50 lakh, even if total consideration exceeds the limit. The Tribunal quashed both AO and CIT(A) orders.
The Tribunal held that use of surplus for land purchase in the society’s name reflects genuine educational intent. It rejected the view that recurring surplus amounts to profit motive and found the earlier inquiry incomplete. The application under Section 10(23C)(vi) was remanded for proper evaluation.
ITAT Chandigarh ruled that CAD software with a short lifecycle and frequent upgrades qualifies as revenue expenditure, enabling full Section 80IC deduction. AO and CIT(A) orders were set aside.
The Tribunal held that the DRP erred in refusing to consider the USAID–AE agreement, which directly established the back-to-back cost-plus-6% model. It ruled that such crucial evidence cannot be dismissed on a procedural technicality and remanded the matter for fresh adjudication.
ITAT Chandigarh held that a Section 148 notice issued by the Jurisdictional AO instead of Faceless AO violated statutory provisions, quashing the assessment for AY 2016-17.
Explains when co-operative societies providing credit to members can claim full deductions under section 80P(2)(a)(i) despite having nominal members.
