The ITAT held that interest earned by a co-operative credit society on bank deposits qualifies as business income. Such income is eligible for deduction under Section 80P(2)(a)(i).
ITAT ruled that mere acceptance of exemption without examining statutory amendments constitutes non-application of mind. The Principal Commissioner rightly invoked Section 263 where binding High Court rulings were ignored.
The Tribunal ruled that failure to verify discrepancies in quantitative stock details justified revisionary action. Mere calling of documents without proper examination invites Section 263 proceedings.
The Tribunal observed that the AO disallowed 50% of warranty provisions and 25% of liabilities without justification. It held that in absence of specific defects in remand proceedings, such ad hoc disallowances cannot survive.
The ITAT ruled that dismissing an appeal solely for non-compliance is contrary to law. The appellate authority is obligated to frame issues and pass a reasoned order on each ground raised.
The AO compared per-location payments to different vendors to allege excessiveness. The Tribunal held that such comparisons lack statutory backing when parties are unrelated and services differ in nature and complexity.
The AO completed assessment under Section 144 after alleged non-compliance, but failed to prove valid service of notice under Section 148. The Tribunal ruled that absence of jurisdiction renders the entire proceedings null.
The PCIT questioned deduction under Section 80JJAA and CSR expenses but failed to record specific findings. The Tribunal held that absence of independent verification and reasoning renders the Section 263 order invalid.
The Tribunal held that reopening beyond three years is impermissible where alleged escaped income is below ₹50 lakh. Since the notice violated Section 151, the reassessment was quashed.
The Tribunal ruled that since the assessment was legally correct when passed, invoking Section 154 after a later Supreme Court decision was impermissible. The addition was consequently deleted.
