Chennai ITAT held that reassessment notices issued after three years must comply strictly with Section 151(ii) approval requirements. Failure to obtain sanction from the proper authority vitiated the entire reassessment proceedings.
The Tribunal ruled that participation by a legal heir does not validate notices and assessment orders issued in the name of a deceased assessee. Proceedings must be initiated strictly under Section 159 against legal representatives.
The Tribunal ruled that the limitation period for appeal commenced only when the assessee first received the ITBA screenshot revealing the basis of the outstanding demand.
The Tribunal ruled that a genuine share transaction resulting in a short-term loss cannot automatically be treated as a make-believe or accommodation entry transaction. The assessee’s regular trading history supported the genuineness of the transactions.
ITAT Mumbai deleted additions exceeding ₹10.57 crore made under section 56(2)(vii)(c) after finding that the Assessing Officer wrongly adopted an amended valuation approach retrospectively. The Tribunal upheld the CIT(A)’s deletion in entirety.
The Tribunal ruled that an assessee following mercantile accounting must offer interest income to tax on accrual basis, irrespective of delayed receipt. Failure to disclose the full accrued amount in the relevant year justified reassessment and addition.
ITAT Mumbai ruled that replacing projected cash flows with actual profits while applying the DCF method is legally impermissible. The decision reaffirmed that DCF valuation is inherently based on future estimates and business expectations.
ITAT Mumbai held that additions under section 68 cannot survive where the Assessing Officer failed to conduct independent verification of alleged accommodation entries. Reliance solely on third-party investigation reports was rejected.
The Tribunal upheld tax addition where agricultural land was acquired below stamp duty valuation and DVO-determined fair market value. It ruled that agricultural status of land does not exclude applicability of section 56(2)(x).
Mumbai ITAT held that additions for alleged accommodation entries and commission income cannot be sustained solely on retracted statements and third-party Tally data without independent corroborative evidence.
