The Tribunal held that the assessee could not deduct tax due to binding interim directions of the High Court. As a result, it could not be treated as an assessee in default under Section 201.
The tribunal held that issuing a show cause notice was invalid where tax liability was already declared in returns. The demand and penalties were set aside as proceedings lacked legal basis.
The Tribunal rejected reopening based on common reasons for multiple years without year-specific justification. The absence of relevant material for AY 2010–11 led to quashing of reassessment. The ruling stresses precision in reopening proceedings.
The Court held that delay caused by reliance on a consultant and personal hardship constitutes sufficient cause. It restored the appeal to ensure adjudication on merits.
The issue was whether reassessment can proceed without disclosing full allegations to the taxpayer. The Court held that failure to provide an opportunity to respond violates natural justice. The key takeaway is that reassessment notices must clearly communicate all grounds.
The issue was whether the insolvency application was time-barred. The Tribunal held that balance sheet entries and revival letters extend limitation under law. The key takeaway is that acknowledgment of debt can revive limitation periods.
The issue was whether sale of agricultural land attracts capital gains tax. The Tribunal held that land situated beyond prescribed municipal limits is not a capital asset. The key takeaway is that location plays a decisive role in taxability.
The issue was whether interest on FDRs qualifies for deduction under Section 80P. The Tribunal held that such income earned from cooperative banks is eligible for deduction. The key takeaway is that interest from cooperative institutions can qualify for exemption.
The issue was whether a single satisfaction note can cover multiple assessment years under Section 153C. The Tribunal held that absence of year-wise satisfaction renders the proceedings invalid. The key takeaway is that jurisdiction requires specific satisfaction for each year.
The case involved detention of goods where the taxpayer cited vehicle breakdown as the cause of delay. The court quashed the order for non-consideration of the reply and remanded the matter for fresh adjudication.
