The issue was whether reassessment can proceed without furnishing recorded reasons despite a taxpayers request. The Tribunal held that failure to supply reasons is a jurisdictional defect that invalidates reassessment.
The issue was whether a recorded share investment can be treated as unexplained under Section 69. The Tribunal held that once an investment is recorded in the books and its source is not doubted, Section 69 cannot be invoked.
The issue was whether income disclosed during survey and duly reported in the return can attract penalty under Section 270A. The Tribunal held that when returned income equals assessed income, penalty provisions do not apply.
The Tribunal ruled that reopening beyond six years is invalid without a recorded satisfaction of undisclosed assets exceeding ₹50 lakh. The takeaway is strict compliance with the fourth proviso to section 153A is mandatory.
The reassessment relied entirely on allegations arising from a search on another entity. The Tribunal ruled that additions cannot survive without independent evidence directly linking the assessee.
The issue was whether reassessment is valid when reasons for reopening are not placed on record. The Tribunal held that non-recording of reasons under Section 148(2) vitiates jurisdiction, rendering the reassessment void.
The Tribunal condoned a 506-day delay after accepting that the appeal was filed only when heavy penalty exposure created prosecution risk. The key takeaway is that bona fide reliance on legal advice and later developments can constitute sufficient cause for condonation.
The issue was whether third-party diaries and loose papers could establish receipt of unaccounted income. The Tribunal ruled that such papers, without authorship verification or corroboration, cannot fasten tax liability.
This ruling clarifies that an assessee can be treated as an agent of a non-resident only if income is received directly or indirectly for the NRI. In the absence of such receipt or business connection, representative assessment fails.
The Tribunal examined whether prior approval under Section 153D was granted after due application of mind. It held that mechanical and routine approval invalidates the assessment, rendering the search assessment void.
