The issue was whether reassessment can continue when all notices are issued in the name of a deceased assessee. The Tribunal held such proceedings void ab initio, as jurisdiction ceases upon death.
The issue was whether the appellate authority could delete a large unexplained investment without following Rule 46A. The Tribunal held that bypassing mandatory procedure invalidates the relief, and the matter must be re-examined.
The issue was whether cash found at a third party’s premises could be added in the assessee’s 153A assessment. The Tribunal held such additions invalid, ruling that proceedings must be initiated under section 153C.
The issue was reopening beyond four years after a completed scrutiny assessment. The Tribunal held the reassessment invalid as there was no finding of failure to disclose material facts, a mandatory precondition under the proviso to section 147.
The issue was whether delayed employees’ PF/ESI contributions paid before filing the return could be allowed. The Tribunal held that the Supreme Court’s interpretation in Checkmate Services is declaratory and applies to earlier years, mandating disallowance.
The issue was whether long-term financing income qualified for deduction despite reclassification of receipts. The Tribunal held the entity eligible, citing statutory changes, past approvals, and consistency across years.
The tribunal ruled that Section 50C could not apply because the DVO’s valuation ignored the impact of tenants and owner-occupied units. The key takeaway is that incorrect valuation methodology invalidates deemed consideration adjustments.
The issue was whether the appellate authority could enhance income by adding entire purchases when the AO had only made a small commission addition. The Tribunal held that such enhancement, without fresh material and beyond the subject matter of appeal, is illegal.
ITAT Hyderabad held that the final assessment order passed by the A.O. u/s. 143(3) r.w.s. 144C(13) r.w.s. 144B dated 06.06.2024 beyond the limitation prescribed under Section 153(4) of the Income-tax Act, 1961 is liable to be quashed. Accordingly, the appeal is allowed.
ITAT Hyderabad held that matter of TP adjustment of purchase of raw materials, assembling parts and sale of goods, and interest on trade receivables is remanded back since there are clear mistakes in computation of margins of comparables.
