The Tribunal held that section 144C cannot be invoked where the TPO proposes no income variation. As the assessee was not an eligible assessee, the assessment was quashed as without jurisdiction.
The Tribunal upheld deletion of additions where loan repayments were sourced from stock sales and fresh loans. It ruled that without rejecting books or disproving records, section 68 cannot be invoked.
The decision reiterates that once the assessees death is known, proceedings must restart with a valid notice to the legal heir. Failure to do so makes the assessment unsustainable.
This case addressed whether tax appeals survive a moratorium under insolvency law. The ruling confirms that income tax proceedings stand stayed once a moratorium is imposed.
Emphasising settled law, the Tribunal ruled that properly documented loan transactions cannot be rejected without cogent contrary material. The CIT(A)s deletion of additions was therefore affirmed.
The Tribunal held that reassessment initiated after three years without approval from the statutorily specified higher authority is invalid. Improper sanction under Section 151 vitiates the entire proceedings.
The issue was whether final assessment orders passed after DRP directions were barred by limitation under section 144C read with section 153. The Tribunal held that such orders passed beyond the statutory time limit are without jurisdiction and must be quashed.
The Tribunal examined suspicion surrounding a large cash advance for property. It ruled that suspicion alone cannot replace evidence, and once the transaction is substantiated, section 68 addition must be deleted.
The Tribunal held that a final assessment passed without giving effect to binding DRP directions violates section 144C. Such an order is void ab initio and cannot be sustained once the statutory time limit has expired.
It was ruled that the date of recording the satisfaction note is the deemed search date for a non-searched person. The ten-year limitation must be counted from this date, not from the original search.
