The issue was whether late-fee under Section 234E could be levied while processing TDS returns before 01-06-2015. The Tribunal held that without Section 200A(1)(c), such levy was without authority of law.
Chennai ITAT set aside the PCIT’s revision order under Section 263, confirming that when the AO adopts a plausible view and conducts proper scrutiny, revision is unwarranted.
The ITAT held that limitation under section 144C(13) starts from the date DRP directions are uploaded on the ITBA portal. A final order passed beyond this deadline was declared void ab initio.
The ITAT held that CPC and CIT(A) acted prematurely in denying section 80P deduction while a section 119 condonation application was awaiting decision. The matter was remanded for fresh adjudication after condonation is decided.
The ITAT held that approval merely stating “Yes, I am satisfied” shows no application of mind. Such sanction fails the statutory requirement and invalidates reopening.
The ITAT held that loans and advances accepted in earlier scrutiny assessments cannot be doubted later without fresh incriminating material. Mere balance-sheet analysis or suspicion is insufficient.
The ITAT held that a reassessment notice issued by the Jurisdictional AO after 29-03-2022 violated the mandatory faceless reassessment scheme. Such a jurisdictional lapse vitiates the entire proceedings.
The ITAT held that disallowance under Section 36(1)(iii) requires factual verification of business purpose. Interest-free loans to group entities were sent back for fresh examination.
The ITAT held that unrecorded sales cannot be taxed in full under Section 69A. Only the profit element at a reasonable GP rate is assessable as business income.
The ITAT held that reassessment based purely on an Investigation Wing report, without the Assessing Officer forming an independent belief, is invalid. Copy-pasted reasons failed to establish a live link between material and escapement of income.
