Recognizing the nature of the manufacturing business and accepted sales, the Tribunal scaled down the disallowance. The decision stresses pragmatic assessment. It avoids penalizing genuine turnover.
The Tribunal clarified that expenditure disallowances do not qualify as assets under section 149(1). Without asset-based escaped income, reopening beyond three years is barred. This offers strong protection against belated reassessments.
The Tribunal held that an intimation making large additions without giving adequate opportunity violates principles of natural justice. The matter was remanded for fresh adjudication.
The Tribunal examined whether website development charges were genuine business expenses. It upheld the disallowance after finding the vendor to be a non-existent entity and services to be unproven.
The Tribunal ruled that setting aside a best-judgment assessment after admitting additional evidence and remand findings is unjustified. CIT(A) must decide the case conclusively instead of granting a fresh lease to the AO.
The Tribunal held that a reassessment notice issued years after the assessee’s death is a legal nullity. Such proceedings are void even if the department was not informed about the death.
Applying settled law, the Tribunal held that penalties imposed after expiry of the limitation period are void. Both loan and repayment penalties were deleted across multiple years.
The Tribunal ruled that reassessment based on borrowed satisfaction, without inquiry or verification by the AO, is unsustainable. Independent application of mind is mandatory under the new regime.
The Tribunal confirmed that once goods are shown to be sold, purchases cannot be treated as wholly fictitious. A limited addition to cover possible inflation was held justified.
Despite large additions for alleged unexplained cash deposits, the Tribunal quashed the reassessment itself. It reaffirmed that jurisdiction cannot be assumed without proper and reasoned approval.
