The issue was whether delayed employees’ PF/ESI contributions paid before filing the return could be allowed. The Tribunal held that the Supreme Court’s interpretation in Checkmate Services is declaratory and applies to earlier years, mandating disallowance.
The issue was whether long-term financing income qualified for deduction despite reclassification of receipts. The Tribunal held the entity eligible, citing statutory changes, past approvals, and consistency across years.
The issue was whether a reassessment could survive when reasons were recorded after issuing notice. The Tribunal held the reopening invalid as the Assessing Officer lacked prior satisfaction, rendering the entire proceedings void.
The issue was whether a holding company with no operating revenue could claim business expenses. The Tribunal held that making strategic investments to control subsidiaries is itself a business activity, allowing expenses and loss set-off.
Delhi ITAT held that issuing notice under section 148 before recording reasons and obtaining approval is a fatal jurisdictional defect. Reassessment initiated without prior satisfaction was declared void ab initio.
The Tribunal ruled that third-party statements cannot be relied upon unless furnished and tested through cross-examination. Natural justice overrides suspicion in section 68 proceedings.
The dispute concerned taxation of land sale as capital gains despite claims that it was agricultural land beyond municipal limits. The Tribunal held that rejecting the claim without examining evidence was improper and remanded the matter for fresh adjudication.
ITAT held that refusal to admit evidence due to factory sealing and death of the assessee was unjustified and ordered fresh assessment after proper verification.
ITAT held that issuing a draft notice with under 24 hours to reply violated natural justice. The assessment and appellate orders were quashed, and the matter was remanded for fresh adjudication with fair opportunity.
ITAT found that the Assessing Officer failed to examine bank statements and supporting documents explaining cash deposits. The issue was restored for fresh verification with due opportunity to the assessee.
