The Tribunal emphasized 33%–40% value addition at the UTK unit and scientific assembly processes to conclude that real manufacturing took place. It directed deletion of disallowances made across five assessment years.
The ITAT Bangalore held that penalty under Section 270A for alleged underreporting and misreporting of income could not survive once the Karnataka High Court condoned the delay in filing the return and restored the assessee’s eligibility for deduction under Section 80IA.
The ITAT Bangalore held that the entire cost of construction claimed by the assessee while computing capital gains on sale of property could not be outrightly disallowed merely due to lack of complete supporting documents.
The ITAT Bangalore held that reopening of assessment was invalid as it was based on an incorrect assumption that the assessee had claimed bogus long-term capital gains (LTCG) from penny stock transactions.
ITAT Bangalore quashed Sec.263 revision, holding AO had examined Model House and ₹9.68 cr expenses in detail; mere change of opinion cannot justify revision.
ITAT Bangalore quashed reassessment for AY 2017-18, holding notice issued on 12-04-2024 time-barred under first proviso to Sec.149(1), despite prior 148A proceedings.
The ITAT Bangalore held that where incriminating documents relating to an assessee are found during a search conducted on another person, the assessment must be framed under Section 153C and not under Section 143(3).
The ITAT Bangalore held that cash received as part of sale consideration for immovable property does not automatically attract penalty under Section 271D if reasonable cause is established under Section 273B.
The ITAT Bangalore held that penalty under Section 271FAA cannot be imposed mechanically where delay in filing the correction statement of financial transactions (Form 61A) is caused by genuine technical and administrative difficulties.
The ITAT Bangalore held that once an Order Giving Effect (OGE) is passed under section 143(3) r.w.s. 254, the Assessing Officer cannot issue a second order for the same assessment year. The Tribunal declared the second OGE non-est and without jurisdiction, dismissing the Revenue’s appeals.
