The Tribunal held that no commission income can arise from circular transactions within group entities. Additions based on estimated commission for such intra-group sales were deleted.
The Tribunal held that an intimation making large additions without giving adequate opportunity violates principles of natural justice. The matter was remanded for fresh adjudication.
The Tribunal examined whether website development charges were genuine business expenses. It upheld the disallowance after finding the vendor to be a non-existent entity and services to be unproven.
Chennai ITAT held that an appellate order passed in the name of a deceased assessee is void in law. The matter must be re-adjudicated after substituting the legal heir.
The Tribunal ruled that setting aside a best-judgment assessment after admitting additional evidence and remand findings is unjustified. CIT(A) must decide the case conclusively instead of granting a fresh lease to the AO.
The Tribunal held that a reassessment notice issued years after the assessee’s death is a legal nullity. Such proceedings are void even if the department was not informed about the death.
Applying settled law, the Tribunal held that penalties imposed after expiry of the limitation period are void. Both loan and repayment penalties were deleted across multiple years.
Mumbai ITAT held that additions cannot be sustained merely due to Form 26AS mismatches. The Assessing Officer must verify whether income was already taxed to avoid double taxation.
Mumbai ITAT held that unexplained bank credits are fully taxable under Section 68 when beneficiaries of accommodation entries are not identified. Mere claim of acting as an entry operator does not limit addition to commission income.
The Tribunal ruled that reassessment based on borrowed satisfaction, without inquiry or verification by the AO, is unsustainable. Independent application of mind is mandatory under the new regime.
