The issue was whether a DRP-based assessment passed after the statutory period survives. The Tribunal held the delay fatal and quashed the assessment in entirety.
The issue was erroneous recomputation of LTCG causing double taxation. The Tribunal held that credit for LTCG already declared must be given and indexation cannot be curtailed arbitrarily.
The Tribunal held that reopening based on unverified Investigation Wing inputs, factual inconsistencies, and no direct nexus to the assessee’s transactions is invalid. Mechanical reproduction of information cannot sustain reassessment.
Rejecting contradictory treatment, the Tribunal ruled that the Revenue cannot approbate and reprobate by accepting the lender’s scrutiny while taxing the borrower under section 68. The addition was therefore deleted.
The Tribunal confirmed that post-2021 reassessment notices must strictly comply with amended section 151. Non-compliance with the specified approving authority deprives the Assessing Officer of jurisdiction.
Applying the test of human probabilities, the Tribunal ruled that unexplained abnormal sales could not be fully accepted. At the same time, absence of book defects warranted estimation instead of outright section 68 taxation.
The Tribunal held that a one-day delay in depositing employees’ PF caused by proven payment gateway failure constitutes impossibility of performance. Genuine attempts and evidence justified allowing the deduction despite strict timelines.
The issue was whether further disallowance could be made after a suo motu 30% disallowance under section 40(a)(ia). The Tribunal ruled that any additional adjustment amounts to double disallowance and is impermissible.
The issue was whether a regular assessment could survive once section 153C was triggered for a non-searched person. The Tribunal ruled that pending scrutiny abates, making an assessment under section 143(3) void from inception.
ITAT Delhi held that cash is duly recorded in the books of accounts hence addition of the same under section 69A of the Income Tax Act as unexplained money. Accordingly, addition rightly deleted by CIT(A). Appeal of the revenue dismissed.
