The Tribunal held that the case transfer under section 127 was invalid as it was passed by a non-jurisdictional authority. Since jurisdiction itself failed, the entire assessment was declared void ab initio.
The case examined whether procedural compliance under section 148A could revive a time-barred reopening. It was held that procedural steps cannot resurrect jurisdiction lost by efflux of time.
The issue was whether penalty can survive once the underlying addition is deleted. The Tribunal held that penalty has no legs to stand when the quantum addition no longer exists.
The issue was whether reassessment can proceed without furnishing recorded reasons despite a taxpayers request. The Tribunal held that failure to supply reasons is a jurisdictional defect that invalidates reassessment.
The issue was whether a recorded share investment can be treated as unexplained under Section 69. The Tribunal held that once an investment is recorded in the books and its source is not doubted, Section 69 cannot be invoked.
The issue was whether income disclosed during survey and duly reported in the return can attract penalty under Section 270A. The Tribunal held that when returned income equals assessed income, penalty provisions do not apply.
The Tribunal ruled that reopening beyond six years is invalid without a recorded satisfaction of undisclosed assets exceeding ₹50 lakh. The takeaway is strict compliance with the fourth proviso to section 153A is mandatory.
The reassessment relied entirely on allegations arising from a search on another entity. The Tribunal ruled that additions cannot survive without independent evidence directly linking the assessee.
The issue was whether reassessment is valid when reasons for reopening are not placed on record. The Tribunal held that non-recording of reasons under Section 148(2) vitiates jurisdiction, rendering the reassessment void.
The Tribunal condoned a 506-day delay after accepting that the appeal was filed only when heavy penalty exposure created prosecution risk. The key takeaway is that bona fide reliance on legal advice and later developments can constitute sufficient cause for condonation.
