ITAT Chennai ruled that an assessment order issued without a Document Identification Number violates CBDT Circular No. 19/2019 and is invalid. Tribunal held that non-compliance with circular’s mandate cannot be cured by later communication of DIN. Orders lacking DIN are deemed never to have been issued.
The appellate authority held that unexplained cash additions under Section 69A require evidence, not mere suspicion. Cash from property sale deposited after ten months was justified and deletion allowed.
ITAT ruled that reassessment under section 147 is valid even if based on an old PAN, as banking and TDS records may reflect its continued use. Ex parte assessment was remanded for proper reconciliation.
The Supreme Court held that revision under Section 263 requires both error and prejudice to revenue. In this case, depreciation claimed by a loss-making entity was tax-neutral, so revision was invalid.
The Tribunal ruled that grants from the Maharashtra Government for road projects were capital in nature. Such promoter’s contributions cannot be taxed as business income.
ITAT Mumbai held that denial of 80G registration due to a wrong section reference was unjustified and directed the Commissioner to reconsider the application on merits.
ITAT Mumbai held that expenses on dies and moulds used in vehicle manufacturing are revenue in nature, not capital, as they involve regular replacements without creating new assets. The Tribunal upheld CIT(A)’s view, citing consistency with past rulings.
Tribunal observed that the legislative amendment allowing condonation of delay reflects intent to grant equitable relief to genuine trusts and directed reconsideration of registration under Section 12AB.
Tribunal held that rent expense differences cannot be taxed as unexplained expenditure without questioning the source. Matter remanded for verification of reconciliation and evidence.
ITAT Mumbai ruled that once the Assessing Officer is aware of a merger, assessment in the name of the amalgamating company is invalid and without jurisdiction.
