The Tribunal held that once the High Court quashed the reassessment for being based on a change of opinion, the additions made in those proceedings could not survive.
ITAT Bangalore held that the Assessing Officer must establish bogus purchases with cogent evidence before making additions. Since the assessee produced complete records and the AO found no defects, the entire addition was deleted.
The Tribunal found that the Assessing Officer failed to issue the fresh notice within the surviving limitation period recognized by the Supreme Court. The reassessment order was therefore quashed.
ITAT Bangalore held that reassessment proceedings were invalid where approval under Section 151 was granted mechanically. The sanction was based on the incorrect assumption that the assessee had not filed a return.
The Tribunal ruled that an assessment order passed after DRP directions is still subject to revision under Section 263. It held that there is no statutory bar preventing the Principal Commissioner from revising such orders.
ITAT ruled that denial of TDS credit due to a PAN mismatch between the deceased and the legal heir is unjustified. Once the income is taxed in the hands of the legal heir, the corresponding TDS credit must also be granted.
The ITAT Chennai held that additions under Section 153A cannot be made for completed assessments when no incriminating material is found during search. Additions based only on special audit findings were therefore quashed.
The case addressed whether tax authorities can issue notices for multiple years based on one satisfaction note. The tribunal ruled that each assessment year requires an independent satisfaction linking seized material.
The Tribunal held that when an adjustment made in the CPC intimation is subsequently deleted in appeal, the scrutiny assessment relying on that adjustment cannot continue. The income was therefore restored to the amount originally declared by the assessee.
Despite disputes over agricultural income additions, the Tribunal focused on the legality of the proceedings. It held that issuing a notice to a deceased taxpayer is a substantive illegality and cannot be treated as a curable procedural defect. The assessment was quashed.
