The Tribunal found that the Assessing Officer failed to issue the fresh notice within the surviving limitation period recognized by the Supreme Court. The reassessment order was therefore quashed.
ITAT Bangalore held that reassessment proceedings were invalid where approval under Section 151 was granted mechanically. The sanction was based on the incorrect assumption that the assessee had not filed a return.
The Tribunal ruled that an assessment order passed after DRP directions is still subject to revision under Section 263. It held that there is no statutory bar preventing the Principal Commissioner from revising such orders.
The ITAT Chennai held that additions under Section 153A cannot be made for completed assessments when no incriminating material is found during search. Additions based only on special audit findings were therefore quashed.
The case addressed whether tax authorities can issue notices for multiple years based on one satisfaction note. The tribunal ruled that each assessment year requires an independent satisfaction linking seized material.
The court analysed whether the reason account blocked falls within the scope of Section 138 of the Negotiable Instruments Act. It held that the provision applies only when dishonour is linked to insufficient funds or lack of arrangement.
The Tribunal held that when an adjustment made in the CPC intimation is subsequently deleted in appeal, the scrutiny assessment relying on that adjustment cannot continue. The income was therefore restored to the amount originally declared by the assessee.
Despite disputes over agricultural income additions, the Tribunal focused on the legality of the proceedings. It held that issuing a notice to a deceased taxpayer is a substantive illegality and cannot be treated as a curable procedural defect. The assessment was quashed.
The tribunal considered whether inconsistent explanations alone justify treating cash deposits as unexplained income. It held that suspicion cannot replace evidence and additions require proper investigation.
The tribunal examined whether the reasons given for late filing of the appeal were sufficient. It ruled that routine administrative workload and grievance handling cannot explain a substantial delay.
