The Tribunal held that deletion of long-term capital gains without examining original partnership records was premature. The matter was remanded for fresh verification of facts and documents.
The Tribunal held that additions based solely on third-party statements and seized digital data cannot survive without allowing cross-examination. The matter was remanded for fresh adjudication after granting due opportunity to the assessee.
ITAT Delhi quashed reassessment issued beyond three years where alleged escapement was only ₹35 lakh. Section 149 bars reopening unless the ₹50-lakh threshold is satisfied.
The Tribunal held that an assessment framed without issuing a compulsory notice under section 153C lacks jurisdiction. Even seized material cannot cure this foundational defect, rendering the order void ab initio.
The Tribunal held that reassessment is invalid where the mandatory notice under Section 143(2) is issued beyond the prescribed time limit. Absence of a valid and timely notice strikes at the very jurisdiction of the Assessing Officer.
ITAT Delhi held that reassessment based on mechanical approval is invalid in law. Sanction must reflect independent application of mind by the approving authority.
ITAT Delhi ruled that expiry of limitation only bars recovery and does not extinguish the debt itself. Outstanding loans remain liabilities unless expressly waived by lenders.
The Tribunal ruled that the Assessing Officer could issue a reassessment notice only within the balance days available after excluding the stayed period. Issuance beyond that surviving window renders the notice time-barred.
ITAT Delhi ruled that granting a common approval for several assessment years violates statutory safeguards. Search assessments collapse if approval is mechanical or omnibus in nature.
The Tribunal found that the AO had examined land records, crop sale documents, and other evidence before making the assessment. Since due inquiry was conducted, the assessment order was neither erroneous nor prejudicial to revenue.
