The Tribunal invalidated reassessment proceedings since the Section 148 notice was issued after 01.04.2021, making it time-barred. The ruling reinforces strict limitation compliance for reopening cases.
ITAT Agra held that the assessee is entitled to claim deduction u/s. 10A of the Income Tax Act before setting off carry forward losses and unabsorbed depreciation. Accordingly, appeal of the assessee succeeds on this ground.
The ruling held that incomplete documentation or minor deficiencies cannot be sole grounds for denial of registration. It emphasized that such issues may be examined during assessment proceedings.
The Tribunal upheld deduction of ESOP expenses under Section 37(1) by relying on binding jurisdictional High Court precedent. It ruled that prior judicial decisions in the assessee’s own case justified deletion of disallowance.
The Tribunal held that recorded sales forming part of turnover cannot be treated as unexplained cash credits. The key takeaway is that taxing gross sales again is impermissible in law.
ITAT Mumbai held that rejection of registration under section 12AB of the Income Tax Act treating receipts and income from sale of agro and Gaushala products as commercial without examining the receipts being incidental and ancillary is not justifiable. Accordingly, matter restored to file of CIT(E).
ITAT confirmed validity of reassessment based on cash deposit information. However, it reduced addition by applying peak credit theory due to withdrawal patterns
ITAT held that failure to record how seized material impacts taxable income invalidates proceedings. All assessments were quashed due to defective satisfaction note.
The Tribunal held that omission of taxable foreign exchange gain in the return attracts penalty. It noted that disclosure during assessment does not absolve liability. The ruling highlights importance of correct income reporting.
The Tribunal observed that the assessee could not participate in proceedings due to lack of knowledge. It remanded the matter to ensure proper hearing and adjudication on merits.