The Tribunal upheld reassessment based on Investigation Wing material alleging accommodation entries. It ruled that such tangible inputs justified reopening despite a completed scrutiny assessment.
The Tribunal held that delayed filing of an audit report cannot justify wholesale disallowance of expenses at the CPC processing stage. Such action falls outside the limited scope of Section 143(1) adjustments.
The Tribunal held that reassessment initiated beyond three years requires approval from the Principal Chief Commissioner or Chief Commissioner. Sanction granted by the PCIT was invalid, rendering the entire reassessment void.
The appeals were rejected without examining additions made by the Assessing Officer. The Tribunal emphasized that appellate remedies cannot be defeated by procedural technicalities and restored the cases.
The Tribunal held that reassessment notices issued after 1 April 2021 for AY 2015-16 are legally unsustainable. Since jurisdiction itself failed under TOLA principles, the entire reassessment was quashed.
The issue was whether SEZ deduction could be denied for alleged late filing of Form 56F. The Tribunal held that filing within the CBDT-extended deadline was valid and CPC erred in disallowance. The ruling confirms that statutory extensions must be honoured in return processing.
No on-money addition was made in the cases of other co-owners of the same property. The ITAT held that the Revenue cannot adopt a contradictory stand on identical facts.
The issue was whether a buyer could be taxed for alleged cash payment based only on the seller’s admission. The Tribunal ruled that in the absence of direct or corroborative evidence, no on-money addition can be sustained in the buyer’s hands.
The Tribunal ruled that the reassessment was time-barred because limitation was wrongly computed from the search date. The key takeaway is that receipt of seized material governs jurisdiction for non-searched persons.
Capital gains arose from land compulsorily acquired by a government authority. ITAT directed the AO to re-examine eligibility for exemption under Section 10(37).
