The case addressed whether tax authorities can issue notices for multiple years based on one satisfaction note. The tribunal ruled that each assessment year requires an independent satisfaction linking seized material.
The Tribunal held that when an adjustment made in the CPC intimation is subsequently deleted in appeal, the scrutiny assessment relying on that adjustment cannot continue. The income was therefore restored to the amount originally declared by the assessee.
Despite disputes over agricultural income additions, the Tribunal focused on the legality of the proceedings. It held that issuing a notice to a deceased taxpayer is a substantive illegality and cannot be treated as a curable procedural defect. The assessment was quashed.
The tribunal considered whether inconsistent explanations alone justify treating cash deposits as unexplained income. It held that suspicion cannot replace evidence and additions require proper investigation.
The tribunal examined whether the reasons given for late filing of the appeal were sufficient. It ruled that routine administrative workload and grievance handling cannot explain a substantial delay.
The tribunal considered whether CPC could rely solely on the original tax audit report to make an adjustment. It held that corrections through revised reports and financial records must be examined before sustaining an addition.
The case involved CPC adjustment denying deduction for employees’ PF contribution deposited after statutory due dates. The tribunal ruled that before the Supreme Court’s later decision, the issue was debatable and could not be adjusted under Section 143(1).
The ITAT Ahmedabad cancelled the penalty under Section 271(1)(c) after setting aside the assessment for fresh adjudication, holding that penalty based on the original order cannot survive once the assessment itself is reopened.
The Tribunal held that approval granted under Section 153D without application of mind was invalid. As a result, search assessments framed under Section 153C for multiple years were quashed.
The ITAT Indore held that penalty under Section 272A(1)(d) cannot survive where the assessment is completed under Section 143(3) after considering the taxpayer’s delayed submissions, as such compliance effectively condones earlier defaults.
