The Tribunal held that reassessment initiated after three years without approval from the statutorily specified higher authority is invalid. Improper sanction under Section 151 vitiates the entire proceedings.
The issue was whether final assessment orders passed after DRP directions were barred by limitation under section 144C read with section 153. The Tribunal held that such orders passed beyond the statutory time limit are without jurisdiction and must be quashed.
The Tribunal examined suspicion surrounding a large cash advance for property. It ruled that suspicion alone cannot replace evidence, and once the transaction is substantiated, section 68 addition must be deleted.
The Tribunal held that a final assessment passed without giving effect to binding DRP directions violates section 144C. Such an order is void ab initio and cannot be sustained once the statutory time limit has expired.
It was ruled that the date of recording the satisfaction note is the deemed search date for a non-searched person. The ten-year limitation must be counted from this date, not from the original search.
The Tribunal deleted both substantive and protective additions made across multiple years on the same alleged receipts. It held that such duplication results in impermissible multiple taxation of identical amounts.
The Tribunal held that discounts given to stockists in pharmaceutical distribution are part of sale transactions on a principal-to-principal basis. As no commission was paid, TDS under section 194H was held inapplicable.
The Tribunal held that where income is offered to tax on receipt basis, TDS credit must be granted in the same year despite timing differences arising from accrual-based deduction by clients.
ITAT held that an old trust could not be denied five-year registration merely due to technical restrictions in the online filing system. Provisional registration was set aside and fresh processing was ordered.
The Tribunal held that CSR expenditure disallowed under Section 37 does not bar deduction under Section 80G. Donations to eligible institutions remain deductible unless specifically excluded by law.
