The Tribunal examined the validity of reopening and multiple expense disallowances. While relief was granted on cash payments and reimbursed interest, statutory interest on taxes was held to be non-deductible.
The Assessing Officer made an ALP adjustment on interest despite the assessee having already added back the full amount under thin capitalization rules. The Tribunal ruled that TP provisions cannot be applied where no expenditure is claimed.
ITAT held that penalties under sections 271D and 271E cannot survive once the underlying additions are deleted. The ruling confirms that penalties collapse with the quantum.
Alleged additions for suppressed sales, disallowances, and capital gains were rendered void once the revision order was quashed. The case underscores the doctrine of consequential invalidity.
ITAT Pune held that penalty not leviable under section 270A of the Income Tax Act since show cause notice failed to specify the applicable limb u/s. 270A(9) under which the penalty was imposed. Accordingly, penalty is quashed and appeal is allowed.
The ITAT held that assessments framed beyond the permissible ten-year block under Section 153C are without jurisdiction. Since the satisfaction note fixed the deemed search year later, earlier years were invalidly assessed.
The Tribunal ruled that absence of DIN on Section 143(2) notices vitiates jurisdiction under Section 147. All reassessment orders were quashed as legally unsustainable.
The Tribunal directed normal taxation, holding that Section 115BBE could not be invoked for the year involved. This reinforces the prospective operation of the higher tax regime.
The Tribunal held that a notice under Section 143(2) issued by a non-jurisdictional officer vitiates the entire assessment. In the absence of a valid jurisdictional transfer, the reassessment was declared non-est in law.
The ruling confirms that Section 14A cannot be invoked mechanically without actual expenditure linked to exempt income. Growth mutual funds earning taxable gains fall outside its scope.
