The Tribunal noted that Form 26AS discrepancies were caused by contracts and TDS continuing in the proprietor’s PAN after business conversion. Since reconciliation was not properly examined, the issue was sent back for fresh adjudication.
ITAT held that invoking Rule 8D without recording dissatisfaction with the assessee’s own disallowance violates section 14A(2). Mechanical application of Rule 8D renders the disallowance legally unsustainable.
The Tribunal clarified that section 80G(2) applies to donor deductions, not trust registration. Since conditions under section 80G(5) were fulfilled, registration was directed to be granted.
The Tribunal ruled that issuing only three hearing notices does not satisfy principles of natural justice. The matter was restored for fresh adjudication with proper opportunity.
The Tribunal held that an assessment under section 153C cannot go beyond the material specified in the satisfaction note. Since additions were based on different material, the entire assessment was quashed.
The Tribunal held that after the High Court invalidated section 153C proceedings, all subsequent tax adjustments including those involving ₹6.68 crore are unsustainable. Judicial finality bars further action.
The Tribunal observed that Form 10-IE was available on record before return processing and should have been considered. The assessment was remanded for fresh adjudication under section 115BAC.
The Tribunal held that once sale receipts are accepted as consideration from immovable property, they cannot be taxed as unexplained money under section 69A. The assessment was remanded for fresh adjudication on merits.
The Tribunal dismissed the Revenue’s appeal, holding that JDA-related income issues had already attained finality. Any attempt to reassess the same income in an earlier year would result in impermissible double taxation.
The Tribunal held that additions made without issuing a mandatory show-cause notice violate CBDT instructions and natural justice. Key takeaway: Procedural compliance is essential for valid assessments.
