The Tribunal ruled that inventory figures from a management Excel sheet, without quantity details or physical verification, cannot form the basis of an addition. Properly recorded GST-compliant sales explained the variance.
Holding that justice requires a reasoned order after hearing both sides, the Tribunal remanded the appeals. Continued non-cooperation may still permit ex parte disposal.
The decision reiterates that section 150 is subject to section 150(2) and cannot revive time-barred or jurisdictionally invalid assessments. Directions to reopen were struck down as unlawful.
The Tribunal held that cancellation of the earlier sale deed restored legal ownership to the assessee’s family. Consequently, compensation received on compulsory acquisition qualified for exemption under section 10(37).
The Tribunal examined whether a third-party seized document could be ignored as a dumb document. It held that once cheque entries in the same document matched recorded transactions, related cash entries could not be disbelieved and addition under section 69C was justified.
The Tribunal held that completed assessments cannot be disturbed under section 153C without incriminating material found during search. Additions based solely on third-party data were ruled invalid.
The Tribunal examined whether a branch office treated as a permanent establishment can deduct head-office cost reimbursements. ITAT held that full cost deduction is mandatory so that only profits attributable to the PE are taxed under Article 7.
The Tribunal considered whether disallowance under section 14A was justified merely because exempt income was earned. It ruled that without corresponding investments in the assessee’s books, section 14A cannot be invoked.
The Tribunal held that reassessment proceedings initiated after the statutory limitation period were invalid. Following the Supreme Courts ruling on reassessment timelines, the entire reopening and resulting additions were quashed.
The Tribunal observed that the transfer pricing adjustment was based on unexplained margin calculations. A fresh working was directed to ensure accurate benchmarking of international transactions.
