The Tribunal deleted both substantive and protective additions made across multiple years on the same alleged receipts. It held that such duplication results in impermissible multiple taxation of identical amounts.
The Tribunal held that a common, perfunctory sanction under Section 153D is invalid. The key takeaway is that lack of independent application of mind vitiates search assessments entirely.
The appeal was dismissed solely on procedural grounds without hearing the assessee. The Tribunal held that the CIT(A) is duty-bound to decide appeals on merits after granting a proper opportunity.
The Tribunal examined whether Section 153A could be applied to the search year itself. It held that invoking Section 153A for the wrong assessment year was invalid, rendering the assessment void.
The Tribunal held that rural agricultural land excluded from capital asset under Section 2(14) cannot be taxed under Section 56(2)(vii)(b). Addition based on stamp duty valuation was therefore deleted in full.
The ITAT held that an assessment made in the name of an amalgamated company is void ab initio, even where proceedings continued after merger intimation.
ITAT Delhi held that Final Assessment Order passed u/s 143(3) r.w.s. 144C(13) passed beyond time limit prescribed under section 153 of the Income Tax Act is barred by limitation. Accordingly, Final Assessment Order is liable to be quashed.
The issue was whether additions could be made for an unabated year without any seized material. The Tribunal held that in the absence of incriminating evidence found during search, the assessment under section 153A was invalid and liable to be quashed.
The case examined whether customer advances reported in service tax returns constituted taxable revenue. The Tribunal ruled that revenue accrues only on execution of conveyance deeds, and advances cannot be treated as under-reported turnover.
The issue was whether final assessment orders passed under the DRP route exceeded statutory time limits. The tribunal held that assessments beyond Section 144C read with Section 153 are void for limitation.
