The Tribunal ruled that increasing assessed income without issuing a notice under section 251 violates natural justice. The case was remanded as ex-parte enhancement beyond the original addition was found legally unsustainable.
Tribunal held that debatable issues fall outside scope of summary adjustments under section 143(1). Denial of exemption based on procedural lapses was therefore unsustainable.
ITAT Bangalore invalidated a reassessment where the assessee was not provided the recorded reasons, emphasizing that reopening notices must be supported by clear, communicated reasons before filing returns.
The Tribunal ruled that depreciation for subsequent years is consequential to the first-year determination of actual cost. Appeals were restored as the base year issue remained undecided.
The Tribunal ruled that routine replacement of plant and machinery parts does not create a new asset or enduring benefit. Such expenses were held to be revenue in nature and fully deductible.
ITAT Bangalore ruled that interest earned by a cooperative society from bank deposits is attributable to its core business and eligible for deduction under Section 80P(2)(a)(i), reversing the denial by lower authorities.
The Tribunal ruled that section 271AAB applies only to undisclosed income found in search, not to routine disallowances from recorded books.
The Tribunal upheld revision after finding that the Assessing Officer accepted explanations without proper verification. The ruling stresses that insufficient enquiry can justify action under Section 263.
The Tribunal held that enhancing profit to 10% without comparables was arbitrary. Past accepted margins around 6% had to guide estimation. Income was directed to be computed at 6%.
The Tribunal clarified that precedents cannot replace factual analysis under TNMM. High-turnover mismatches justified exclusion, but other comparables required verification. The ruling underscores disciplined TP benchmarking.
