The Tribunal sent the matter back to the Commissioner (Appeals) for fresh adjudication after the assessee challenged the validity of the Section 148 notice. The issue relating to notices issued by a Jurisdictional Assessing Officer instead of a Faceless Assessing Officer was left open for reconsideration.
The Tribunal upheld the addition after finding that excess stock discovered during survey was physically verified and admitted by the assessee. The later retraction was rejected as unsupported and delayed.
ITAT Amritsar held that reassessment proceedings were invalid because the reopening was based on factually incorrect AIR information. The Tribunal ruled that failure to verify bank records before issuing notice showed non-application of mind.
ITAT Chandigarh held that reassessment proceedings were invalid because the Assessing Officer relied on factually incorrect assumptions regarding the filing of return and property purchase. The reopening was therefore quashed as unsustainable in law.
ITAT Chandigarh held that reassessment proceedings were invalid because the Assessing Officer recorded incorrect facts regarding the return filing date and declared income. The Tribunal ruled that such defective reasons could not support a valid belief of escaped income.
The ITAT Hyderabad held that no under-reporting of income existed where the income declared in the return filed under Section 148 was accepted without any addition. The penalty under Section 270A was deleted.
The ITAT held that reassessment cannot be sustained when the Assessing Officer merely relies on an Investigation Wing report without independent verification. The reassessment order was quashed due to lack of independent application of mind.
The dispute concerned whether deduction under Section 80IB should be reduced by the amount already allowed under Section 80HHC. ITAT held that deductions can be computed independently, provided the aggregate deduction does not exceed eligible profits.
The Tribunal held that the assessee’s delayed appeals warranted condonation in light of an earlier decision on similar facts. The appeals were sent back to the CIT(A) for adjudication on merits.
The appeal was dismissed as time-barred due to a 43-day delay in filing. ITAT held that medical records substantiated the assessee’s health issues and restored the appeal for decision on merits.
