The Tribunal held that reassessment notices issued after 01.04.2021 for AY 2015-16 are time-barred. Such reopening is invalid despite reliance on TOLA, and must be quashed.
The Tribunal held that late filing of Form 10CCB is a procedural lapse. Deduction cannot be denied when the audit report is filed before assessment processing.
Holding that actions prescribed by statute must be performed only in the specified manner, the Tribunal deleted the penalty. The case reinforces the importance of lawful service of notices before penal action.
The tribunal held that dismissal for delay and confirmation on merits without effective hearing violated principles of natural justice, warranting remand for fresh adjudication.
The Tribunal upheld taxation of enhanced compensation and interest under land acquisition after insertion of section 56(2)(viii). The ruling confirms that such receipts are taxable despite earlier judicial views.
The Tribunal found that additions under section 69A were made without examining evidence due to non-compliance. The matter was remanded to allow verification of claimed trading and agricultural receipts.
The tribunal held that reassessment initiated through a jurisdictional officer instead of the mandatory faceless mechanism was invalid. Notices under Section 148 issued after 01.04.2021 must follow the faceless scheme, failing which the entire assessment collapses.
The tribunal held that dismissal for non-prosecution was invalid where notices were not served on the email ID specified in Form 35. Authorities must strictly follow the communication mode chosen by the taxpayer, failing which proceedings are vitiated.
Additions were deleted after finding that the Revenue relied on presumptions rather than tangible proof. The decision reinforces that the burden to prove undisclosed income lies on the tax authorities.
The case examined whether full purchase disallowance was justified without rejecting books of account. The Tribunal held that in such circumstances, only a reasonable profit element could be added.
