The ITAT held that when reassessment is annulled for jurisdictional defects under the faceless regime, the connected concealment penalty cannot stand.
The issue was whether additions could be made for an unabated year without any seized material. The Tribunal held that in the absence of incriminating evidence found during search, the assessment under section 153A was invalid and liable to be quashed.
The Tribunal held that overseas shares acquired from reinvested dividends cannot be taxed as undisclosed assets when the source is known and accepted. Mere omission of dividend income does not trigger the Black Money Act’s harsh provisions.
The issue was whether revision under Section 263 was valid when the AO allowed Section 80P deduction after enquiry. The tribunal held that a plausible and correct view cannot be revised.
The case examined whether customer advances reported in service tax returns constituted taxable revenue. The Tribunal ruled that revenue accrues only on execution of conveyance deeds, and advances cannot be treated as under-reported turnover.
The issue was whether final assessment orders passed under the DRP route exceeded statutory time limits. The tribunal held that assessments beyond Section 144C read with Section 153 are void for limitation.
The dispute concerned the correct terminal point for computing six assessment years under section 153C. The Tribunal held that using the search date instead of the satisfaction date vitiated the entire assessment.
The Tribunal held that revision under section 263 is invalid where the Assessing Officer has already conducted enquiries and taken a conscious view. Mere inadequacy of enquiry does not justify revision.
The Tribunal held that cash withdrawn from disclosed bank accounts and duly recorded in books cannot be treated as unexplained money merely due to doubts on utilisation, in the absence of adverse evidence.
The issue was whether the appellate authority could bypass jurisdictional objections by remanding the case. The tribunal held that legal grounds striking at jurisdiction must be adjudicated first.
