The issue was whether Section 153C could apply when the assessees own premises were searched. The tribunal held that such a person is a searched person, making Section 153A applicable instead. Consequently, assessments under Section 153C were quashed for multiple years.
The issue concerned failure to follow tribunal remand directions on comparables. The ruling held that such non-compliance caused procedural irregularity, leading to exclusion of certain comparables and recomputation of ALP.
The issue was whether a fresh registration application can be rejected due to prior denial. ITAT held that earlier rejection does not bar reconsideration if conditions are fulfilled.
The tribunal addressed whether delay in filing appeals due to procedural difficulties justified condonation. It held that genuine hardship caused by PAN mismatch and filing issues constituted sufficient cause, allowing the appeal.
The Tribunal restored the penalty matter as the quantum addition was sent back to the AO. It held that penalty must follow the outcome of reassessment proceedings.
The tribunal ruled that rejection of Section 54F deduction was premature as the assessee later produced relevant documents. It directed reassessment to verify evidence and ensure proper hearing.
The tribunal reversed the CIT(A)’s decision for wrongly quashing assessment due to lack of notice under Section 143(2). It held that Section 263 proceedings are a continuation of original assessment.
The ruling holds that deposits made from surplus business funds are part of operational activity. Interest earned on such deposits is business income and not income from other sources. Therefore, Section 80P benefit was granted.
The case examines whether penalty can be levied when the quantum issue is admitted by the High Court. The Tribunal held that admission of substantial questions of law makes the issue debatable. As a result, penalty under Section 271(1)(c) was rightly deleted.
The issue was whether high-turnover companies can be compared with a smaller software service provider. The Tribunal held that companies with disproportionately large turnover must be excluded as they distort comparability due to scale advantages.
