The Tribunal held that AY 2010-11 was outside the permissible ten-year assessment block computable under Section 153A. Applying the Delhi High Court’s interpretation in Ojjus Medicare, it found the notice itself invalid. As a result, the assessment proceedings were quashed and the appeals were allowed.
The Tribunal held that donations qualifying under Section 80G do not become ineligible merely because they are incurred as part of CSR obligations. The deduction was allowed following earlier decisions in the assessee’s own case.
The Tribunal held that disallowance of 20% of total purchases was unsustainable where the Assessing Officer had accepted sales, stock records, and quantitative details. Mere non-service of notices under Section 133(6) could not justify treating all purchases as bogus.
ITAT found that the taxpayer’s foreign investment was funded through disclosed banking channels and tax-paid funds. Since there was no deliberate concealment, the penalty was deleted.
The Tribunal found that bank documents showing repayment of the loan were relevant for deciding the Section 68 issue. The matter was remanded to the Assessing Officer for fresh examination.
The Tribunal found that CBDT notifications issued under TOLA extended the period for departmental actions, including rectification proceedings, thereby saving the order from being time-barred.
The Tribunal held that for AY 2015-16, the six-year limitation period under the unamended law expired on 31.03.2022. Since the notice under Section 148 was issued on 23.04.2022, it was time-barred. The reassessment proceedings and consequential assessment order were therefore quashed.
The Delhi ITAT upheld deletion of a ₹14.20 crore addition under Section 68, holding that the AO relied on old search findings and failed to bring any direct evidence against the assessee’s loan transactions.
The Tribunal ruled that disallowance of deduction under Section 80P was beyond the permissible scope of prima facie adjustments under Section 143(1). Relief was granted to the assessee.
ITAT Delhi held that high sea sales could not be treated as non-genuine where customs approvals, sale agreements, and delivery records established the transactions. The Tribunal deleted the ₹59.11 crore addition and ruled that Section 68 could not apply to recovery of sale consideration.
