The issue centred on whether chilling is merely cooling or a technical process. The Tribunal held that chilling involves scientific tests and preservation steps, constituting processing under the Act and justifying the deduction.
The assessee relied on deemed payment after transferring employee dues to another entity. The Tribunal ruled that section 43B recognises only real payment and set aside the relief granted by the appellate authority.
The Assessing Officer treated all cash deposits as unexplained income under Section 115BBE. The Tribunal held that deposits prima facie represented IOC sales and required factual verification before any addition.
The dispute concerned whether transfer through a release deed amounted to a taxable sale and justified loss claims. The Tribunal remanded the matter, directing verification of books to examine the genuineness of the claimed loss.
The issue concerned reassessment initiated through a non-faceless notice despite a binding notification. The ruling confirms that violation of the faceless framework vitiates reassessment proceedings.
The Tribunal held that reassessment based on a notice issued by the wrong authority cannot survive in law. The decision highlights strict adherence to procedural requirements under the faceless regime.
The Tribunal upheld the CIT(A)’s power to remand an ex-parte assessment for fresh adjudication. It ruled that such action was within jurisdiction, leading to dismissal of the Revenue’s appeal.
The issue was whether penalty could survive after the assessment order was set aside. The Tribunal held that once the basis of the addition is extinguished, penalty under Section 271(1)(c) cannot be sustained.
The Tribunal held that reassessment remains valid when the notice is issued while the company is still on the ROC records. Subsequent striking off does not nullify initiated proceedings.
The Tribunal found that reasonable opportunity was not given at assessment or appellate stage. The ₹17.94 lakh addition was remanded for fresh adjudication.
