The Tribunal held that a common, perfunctory sanction under Section 153D is invalid. The key takeaway is that lack of independent application of mind vitiates search assessments entirely.
The ITAT held that equipment received free of cost for testing purposes does not constitute a taxable business benefit. It ruled that once the receipt itself is not taxable, no notional mark-up can be added.
The case examined denial of section 11 exemption at the processing stage due to late filing of Form 10B. The Tribunal ruled that such delay is a curable procedural defect and cannot justify denial of exemption.
The Tribunal held that a one-day delay in filing Form 10IE for an earlier year cannot defeat the assessee’s right to be taxed under the new regime. The assessee was directed to be taxed under Section 115BAC for AY 2023–24.
Professional fees and foreign branch expenses incurred by a strategic investment company were allowable under Section 37(1) in the absence of any finding that the expenditure was excessive, unreasonable
The appeal was dismissed solely on procedural grounds without hearing the assessee. The Tribunal held that the CIT(A) is duty-bound to decide appeals on merits after granting a proper opportunity.
The Tribunal examined whether Section 153A could be applied to the search year itself. It held that invoking Section 153A for the wrong assessment year was invalid, rendering the assessment void.
The Tribunal held that rural agricultural land excluded from capital asset under Section 2(14) cannot be taxed under Section 56(2)(vii)(b). Addition based on stamp duty valuation was therefore deleted in full.
The Tribunal held that serving notices on an outdated email ID violates principles of natural justice. The assessment was set aside and the matter restored for fresh adjudication after proper service.
The ITAT held that income addition based solely on Form 26AS differences cannot survive when books are audited and no defects are found.
