Emphasising strict compliance, the Tribunal ruled that assessments under section 153A without prior section 153D approval are invalid. Cross-objections became infructuous once Revenue appeals were dismissed.
The case examined whether general search statements can justify additions under section 68. The Tribunal held that without a cash trail or independent enquiry, such statements cannot override documentary proof.
The Tribunal held that section 144C cannot be invoked where the TPO proposes no income variation. As the assessee was not an eligible assessee, the assessment was quashed as without jurisdiction.
The dispute concerned denial of TDS credit citing inconsistencies in reported transaction values. The ruling clarified that Form 26AS is decisive for TDS credit when deduction and deposit are undisputed.
The Tribunal upheld deletion of additions where loan repayments were sourced from stock sales and fresh loans. It ruled that without rejecting books or disproving records, section 68 cannot be invoked.
The Tribunal considered whether RTGS credits constituted unexplained money. It ruled that once sale bills, customer ledgers, and bank entries align, Section 69A has no application.
The decision reiterates that once the assessees death is known, proceedings must restart with a valid notice to the legal heir. Failure to do so makes the assessment unsustainable.
This case addressed whether tax appeals survive a moratorium under insolvency law. The ruling confirms that income tax proceedings stand stayed once a moratorium is imposed.
Emphasising settled law, the Tribunal ruled that properly documented loan transactions cannot be rejected without cogent contrary material. The CIT(A)s deletion of additions was therefore affirmed.
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.
