The issue was whether final DRP-based assessments passed beyond statutory timelines are valid. The Tribunal held that limitation under Section 144C must be read with Section 153, rendering delayed final orders void.
The Tribunal held that the case transfer under section 127 was invalid as it was passed by a non-jurisdictional authority. Since jurisdiction itself failed, the entire assessment was declared void ab initio.
The Tribunal examined whether prior approval under Section 153D was granted after due application of mind. It held that mechanical and routine approval invalidates the assessment, rendering the search assessment void.
The reassessment was challenged for lacking approval from the correct authority under Section 151 after three years. The Tribunal held that sanction by an incorrect authority vitiates jurisdiction, rendering the reassessment void.
The issue was whether DRP cases escape the outer limitation under section 153. The Tribunal held that section 153 continues to apply and quashed the assessment as time-barred.
The issue was whether additional rental income could be treated as undisclosed. The Tribunal held that tenant confirmations and bank records proved the declared rent, leading to deletion of the addition.
The issue was whether the entire purchase amount could be added under Section 69C based solely on an entry-operator’s denial. The Tribunal ruled that since sales were accepted and books not rejected, only a 10% estimated disallowance was justified.
The ITAT ruled that absence of recorded satisfaction in the assessment order bars initiation of penalty under Section 271E. Supervisory revision cannot substitute the Assessing Officer’s statutory discretion.
The Tribunal ruled that reassessment cannot survive when the final addition departs from the original Section 148A notice. Consistency of information throughout the reopening process is mandatory.
The Tribunal ruled that exemption for charitable trusts cannot be denied merely due to belated filing of Form 10B. It reaffirmed that the requirement is directory, not mandatory, when the audit report is eventually furnished.
