The Tribunal ruled that absence of DIN on Section 143(2) notices vitiates jurisdiction under Section 147. All reassessment orders were quashed as legally unsustainable.
The Tribunal directed normal taxation, holding that Section 115BBE could not be invoked for the year involved. This reinforces the prospective operation of the higher tax regime.
The Tribunal held that a notice under Section 143(2) issued by a non-jurisdictional officer vitiates the entire assessment. In the absence of a valid jurisdictional transfer, the reassessment was declared non-est in law.
The ruling confirms that Section 14A cannot be invoked mechanically without actual expenditure linked to exempt income. Growth mutual funds earning taxable gains fall outside its scope.
The Tribunal held that compensation received for unauthorised occupation merely substitutes lost rent. Since the property remained intact, the receipt was taxable as revenue income under Section 23(1).
ITAT held that assessing an AOP without initiating reassessment proceedings against it is impermissible in law. The entire reassessment was declared non-est and additions were deleted.
The Tribunal restricted additions on demonetization-era cash deposits where books were audited and not rejected. Only a nominal amount was sustained to balance equity.
The Tribunal ruled that denial of Section 54F relief without proper verification was premature. The Assessing Officer must re-examine ownership and payment evidence before deciding the claim.
The Tribunal held that a loan repaid through banking channels cannot be treated as unexplained when identity and creditworthiness are shown. Allegations based on untested statements were rejected.
The dispute centered on whether commission recipients actually rendered services. The tribunal ruled that in absence of summons, rejection of books, or contrary evidence, the expense could not be disallowed.
