The court held that parties cannot introduce additional evidence as a matter of right under Rule 29. The ITAT’s acceptance of Revenue-filed evidence and remand order was set aside as beyond jurisdiction.
The issue involved rejection of an appeal against GST cancellation on limitation grounds. The Court granted relief by following consistent precedents, allowing restoration subject to compliance conditions.
The court held that revision under section 263 requires independent satisfaction by the PCIT. Acting merely on the Assessing Officer’s view renders the revision order invalid.
The case addressed whether a special audit can be ordered without establishing complexity or defects in accounts. The Court examined whether mechanical invocation of Section 142(2A) without proper justification is legally sustainable.
The Court ruled that the reassessment notice was invalid as it exceeded the statutory 10-year limit under Section 153A. It clarified that the search year must be included in computing the extended limitation period.
The case examined whether separate penalties under CGST and SGST were permissible. The Court ruled such imposition unjustified and restricted the penalty to ₹25,000.
The Court held that reassessment proceedings are invalid if approval is obtained from an incorrect authority. It clarified that sanction must strictly comply with Section 151 based on elapsed time limits. The ruling reinforces jurisdictional safeguards in reassessment cases.
The Court held that reassessment based solely on an audit objection is invalid as it constitutes a change of opinion. It emphasized that previously examined issues cannot be reopened without new tangible material. The ruling reinforces limits on reassessment powers.
The Court held that failure to consider a filed reply invalidates the assessment. The matter was remitted for fresh adjudication with hearing opportunity.
The Court examined whether GST cancellation for non-filing of returns could be reversed. It held that authorities must consider restoration if the taxpayer files pending returns and pays dues. The key takeaway is that compliance can enable reconsideration of cancellation.
