The issue was whether cash salary and commission payments attracted disallowance under section 40A(3). The ITAT held that since each payment was below the per-day statutory limit, the disallowance of ₹2.75 crore was unsustainable.
The issue was whether property investment could be treated as unexplained in reassessment proceedings. The ITAT held that where bank trails, NRE accounts, and loan documents fully explain the source, additions cannot survive.
The Tribunal held that a minor delay in filing Form 10B is a procedural lapse and not fatal to exemption under section 11. Substantive charitable benefits cannot be denied for trivial delays.
The Tribunal held that commission paid to a shell concern with no real services is taxable as unexplained credit. Claims that expenditure related to an earlier year were rejected.
The Tribunal remanded the case involving addition of crypto closing stock after finding procedural defects. The appellate authority must first decide limitation before examining merits.
The Tribunal held that a transfer pricing reference made after expiry of assessment limitation is void. Once time has run out under section 153, subsequent TPO action cannot resurrect the assessment.
The Tribunal ruled that once the original notice itself is jurisdictionally invalid, later compliance with section 148A is irrelevant. Foundational defects cannot be remedied procedurally.
ITAT Chandigarh held that passing of final assessment order under section 153A of the Income Tax Act without issuing draft assessment orders under section 144C of the Income Tax Act is untenable. Accordingly, final assessment order u/s. 153A is quashed.
The Tribunal held that when sales are not disputed, the entire value of alleged bogus purchases cannot be added under section 69C. Only the embedded profit element is taxable.
The assessment was quashed because the mandatory notice under section 143(2) was issued by an officer lacking jurisdiction. The ruling confirms that jurisdiction must exist at the notice stage itself.
