The Tribunal held that proceedings under Section 153C were invalid because the satisfaction note did not record that the seized material had a bearing on the determination of the assessee’s total income. The assessment was quashed.
The Tribunal held that proceedings under Section 153C were invalid because the satisfaction note did not record that the seized material had a bearing on the determination of the assessee’s total income. The assessment was consequently quashed.
The Tribunal held that additions relating to share capital and share premium required fresh examination after considering the assessee’s documentary evidence and offer to produce investor-company directors. The appeal was allowed for statistical purposes.
The ITAT Delhi held that a notice under Section 143(2) issued by an Assessing Officer lacking jurisdiction cannot confer valid authority to complete an assessment. It quashed the assessment after finding that the jurisdictional officer also failed to issue a fresh statutory notice.
The ITAT held that a scrutiny assessment cannot survive where the jurisdictional Assessing Officer failed to issue the mandatory notice under Section 143(2). It ruled that the defect rendered the entire assessment void ab initio despite transfer of the case.
The ITAT Delhi held that an assessment order passed through e-Proceedings must be digitally signed as required by CBDT Instruction No. 1/2018. Since the order was manually signed without any prescribed exception, it was quashed.
The ITAT Delhi held that the final assessment order was time-barred as it was passed beyond the mandatory period prescribed under Section 144C(13). The Tribunal ruled that internal departmental communications could not extend the statutory limitation and quashed the assessment.
The Tribunal held that penalty under Section 271D could not be levied because the Assessing Officer failed to record satisfaction for initiating such proceedings in the assessment order. The penalty was cancelled following the Supreme Court’s ruling.
The Tribunal held that an unsigned loose paper containing only jottings could not justify an addition without corroborative evidence. The addition of alleged interest income was therefore deleted.
ITAT Delhi held that an assessment framed after an approved merger in the name of the amalgamating company was without jurisdiction. The assessment order and DRP directions were set aside because the company had ceased to exist.
