The ITAT held that denying registration without adequate opportunity is invalid. Authorities must fairly examine replies and documents before rejection.
The dispute concerned computation of capital gains on sale of shares affected by corporate actions. The Tribunal affirmed that detailed tranche-wise analysis and statutory indexation justified allowance of long-term capital loss.
The issue was whether a penalty could survive when the notice failed to specify the exact limb of section 271(1)(c). The ITAT held such ambiguity fatal, quashing the entire penalty as void.
ITAT Delhi overturned a ₹2.61 crore addition under sections 144/147, noting notices were sent to the wrong address and the illiterate assessee was deprived of proper hearing.
The ITAT Delhi ruled that a single approval for seven assessment years under Section 153D, issued without application of mind, is invalid, quashing the related assessment orders. The case underscores the need for careful, year-specific scrutiny.
The ITAT held that limitation under section 144C(13) starts from the date DRP directions are uploaded on the ITBA portal. A final order passed beyond this deadline was declared void ab initio.
The question was whether the extended ten-year window under Section 153C could be invoked. The Tribunal held that where the satisfaction note shows escaped income below ₹50 lakh, the extended limitation is unavailable.
The ITAT noted that cash-flow statements showing withdrawal–redeposit nexus were not examined. Non-consideration of material evidence warranted remand.
ITAT Delhi held that without a clear and direct connection between the facts and the alleged escapement of income, the reasons recorded remains speculative, therefore, the reopening cannot be justified. Accordingly, appeal allowed to that extent.
The ITAT held that reassessment based on a duplicate PAN, despite disclosure under a valid PAN, suffers from jurisdictional infirmity. Ex parte orders passed without addressing such objections violate principles of natural justice.
