The Tribunal held that revision cannot be based on alleged lack of enquiry when detailed verification was already done. A mere change of opinion does not justify section 263 action.
Applying the timelines prescribed in Rajeev Bansal, the Tribunal found the notice issued after the permissible window. The ruling reinforces strict adherence to limitation in reassessment cases.
The Tribunal held that a notice dated 31.03.2021 but dispatched after 01.04.2021 is governed by the new reassessment regime. Failure to follow section 148A procedures rendered the entire reassessment void.
The Tribunal held that Dividend Distribution Tax is effectively a tax on shareholder dividend income and is subject to DTAA benefits. Excess tax collected above the treaty rate was ordered to be refunded.
The Tribunal held that when interest-free own funds exceed investments, no interest disallowance under section 14A can be made. The ruling reinforces that presumption favours the taxpayer in such cases.
ITAT Pune held that provision of interest on loan from state government is ascertained liability and hence couldn’t be disallowed under section 37 of the Income Tax Act. Accordingly, the appeal is allowed.
The assessee demonstrated that the ₹1.03 crore cash deposit arose from opening cash balance and collections from sundry debtors. The Tribunal held that the onus stood discharged and deleted the entire addition.
ITAT held that CPC cannot increase dividend income based on Schedule BP entries, restricting taxable dividend to the amount correctly disclosed in the return and upholding section 115BBDA exemption.
The Assessing Officer proceeded with reassessment after three years based solely on PCIT approval. The Tribunal emphasized that compliance with Section 151 is mandatory, and failure renders the notice under Section 148 void.
Reassessment was quashed as the statutory process under the faceless regime was not followed end-to-end by the same authority. Such jurisdictional inconsistency vitiates the entire proceedings.
