The ITAT held that revisional powers under Section 263 cannot be exercised when the Assessing Officer has already examined the issues during scrutiny. Mere disagreement with the assessment cannot justify revision.
Delhi High Court held reassessment under Sections 147/148 cannot be initiated merely on an internal audit objection. Absence of new tangible material made reopening invalid.
The High Court held that reassessment cannot be based on grounds not mentioned in the original Section 148A notice. Since no income had escaped assessment, the reopening was quashed.
The issue was whether ITAT could reject appeals after an administrative transfer. The High Court ruled such dismissals are invalid and appeals must be heard on merits.
The tribunal held that a partner’s capital account increase arising from a firm’s loan write-back cannot be taxed under Section 68. The key takeaway is that such credits are only accounting consequences, not unexplained income of the partner.
ITAT held that execution of a registered joint development agreement amounts to transfer of land. Capital gains timing must be determined from that date, not a later year chosen by the assessee.
The Tribunal held that reopening after four years is invalid without alleging failure to disclose material facts. The reassessment was barred by the proviso to section 147.
The issue concerned valuation of royalty for bundled services. ITAT held that faulty comparables vitiated the CUP analysis and ordered fresh benchmarking.
The Supreme Court held that capital gains from indirect transfers deriving value from Indian assets were taxable in India. The key takeaway is that treaty protection cannot shield arrangements lacking real commercial substance.
The Tribunal held that unexplained cash credit addition cannot survive once identity, genuineness, and creditworthiness are established through documentary evidence. The key takeaway is that mere low income of creditors is insufficient without contrary investigation.
