The ITAT held that assessments under Section 153A were invalid because no search warrant was issued in the assessee’s name. As the foundational assessment was void, the consequential Section 263 revision orders were also quashed.
The ITAT held that limitation under Section 153B must be determined based on the assessee’s own last panchanama despite a joint search warrant. As the assessments were completed beyond the prescribed period, they were quashed.
The ITAT Hyderabad held that the assessment orders were time-barred under Section 153 despite the DRP process. Both assessments were quashed after applying the limitation prescribed under the Act.
The ITAT held that limitation under Section 153B had to be computed from the searched person’s last panchanama, making the assessments time-barred. The assessment orders were therefore quashed.
The Tribunal held that the addition under Section 68 could not be sustained because the assessee produced complete documentary evidence supporting the share transactions. It ruled that the Assessing Officer failed to bring any cogent material to rebut the evidence or justify denial of Section 10(38) exemption.
The ITAT Pune upheld the deduction under Section 10AA after finding that the Assessing Officer had not established that the SEZ units were formed by splitting up or reconstruction of an existing business. It followed earlier decisions in the assessee’s own case.
The ITAT Mumbai held that Explanation 1 to Section 37(1) could not apply in the absence of any finding by the competent authority that the assessee had committed an offence or violated the Insurance Act. The disallowance was therefore deleted.
The Mumbai ITAT upheld deletion of notional interest on interest-free advances to a subsidiary, finding the issue consistently decided in earlier years. The Tribunal held that, in the absence of changed facts, the CIT(A) rightly followed binding precedents.
The ITAT Pune held that deletion of the addition was premature as the source of cash payments reflected in seized diaries had not been properly examined. It remanded the matter to the CIT(A) for fresh verification.
The ITAT Hyderabad upheld deletion of a ₹68.75 crore Section 68 addition after finding that the partner had established the source of capital contribution through sale proceeds of land. The Tribunal held that documentary evidence sufficiently explained the capital introduced into the firm.
