The Tribunal dismissed the appeals as time-barred since no application for condonation of delay was filed despite repeated opportunities. In the absence of any explanation, the appeals were held not maintainable.
The Tribunal held that a notice issued under section 148 on 31.07.2022 for AY 2014-15 was barred by limitation under the amended section 149. Reassessment proceedings were quashed as void ab initio.
ITAT Pune condoned an 897-904 day delay in appeals, holding the delay was unintentional and due to incorrect guidance. The case highlights that bona fide professional errors can justify condonation of delay.
Mumbai ITAT upholds deletion of ₹70 lakh under Section 69, ruling that uncorroborated WhatsApp scribbles from a third party cannot establish unexplained cash income.
he tribunal held that an appellate order based on an incorrect and reconstructed timeline of statutory notices is unsustainable. Errors in sequencing of notices strike at the root of jurisdiction and require fresh adjudication.
ITAT Mumbai ruled that for redeveloped flats, the allotment date marks acquisition, confirming long-term capital gains eligibility under section 54, despite later possession.
The tribunal ruled that section 263 cannot be invoked merely because the Commissioner believes further enquiry was possible. Unless the order is unsustainable in law, revision on alleged inadequate enquiry is impermissible.
Applying a liberal approach, the tribunal condoned delay in appeal filing and examined the jurisdictional defect. Since reopening was initiated by the wrong authority, the assessment could not survive.
The tribunal held that when the assessment order is remanded for de-novo adjudication, the very basis for penalty ceases to exist. Consequently, penalty proceedings under section 271(1)(c) become unsustainable.
The tribunal held that delay in filing Form 10BB is only a procedural lapse and not a substantive bar to exemption. Where the audit report was available before processing, denial of section 11 exemption was unsustainable.
