ITAT held that reassessment initiated with approval from the wrong authority is invalid when issued beyond three years. The entire proceedings were quashed. The key takeaway is that proper sanction under Section 151 is mandatory.
ITAT held that estimating profit at 8% without considering records was excessive. It reduced the rate to 3% based on business realities. The key takeaway is that estimation must be reasonable and evidence-based.
ITAT rejected condonation of a 963-day delay as the assessee failed to provide supporting evidence for the reasons stated. The Tribunal held that mere claims without proof cannot justify delay.
The Tribunal condoned a delay of 615 days after finding that the assessee was actively pursuing rectification remedies under Section 154. It held that such bona fide conduct constitutes sufficient cause and delay cannot be treated as negligence.
ITAT held that an unexplained delay of over 11 years cannot be condoned without valid reasons. The appeal was dismissed as no sufficient cause was proved.
ITAT held that late filing of Form 67 is only a procedural lapse and not a ground to deny FTC. The matter was remanded for verification and grant of eligible credit.
The case involved additions made solely on an Excel sheet and a third-party statement alleging cash payments. The Tribunal ruled that such unverified material, without independent evidence, cannot justify additions.
The issue was whether penalty applies when a bogus donation claim is withdrawn after detection. The Tribunal held that post-detection withdrawal is not voluntary, and penalty for misreporting was rightly imposed.
The issue was whether reassessment can survive when no addition is made on the stated reasons for reopening. The Tribunal held that such reassessment is invalid, and the AO cannot make unrelated additions.
ITAT held that reassessment without issuing notice under Section 143(2) is invalid, even if return was filed late. The ruling emphasizes that issuance of notice is mandatory and absence of it makes the assessment void.
