The ITAT held that reassessment issued after three years is void if approval is taken from an incompetent authority. Wrong sanction under section 151 renders the entire reopening unsustainable in law.
The ITAT held that undated satisfaction notes defeat jurisdiction under section 153C. In such cases, limitation must be computed from the notice date, making assessments beyond the block period void.
The ITAT ruled that acknowledging donors at religious events does not amount to commercial advertising. Voluntary donations used for religious purposes retain exemption under section 11 despite name displays.
The ITAT held that additions under section 153A for unabated years require incriminating material found during search. Suspicion, past records or third-party allegations cannot substitute seized evidence.
The ITAT held that warranty provisions based on past experience are deductible even if a sizeable opening balance exists. Estimated future obligations from past sales qualify as allowable business expenditure.
The ITAT ruled that section 69A cannot be invoked unless ownership of cash is established. Mere third-party seized ledgers without recovery of money are insufficient to sustain an addition.
The Tribunal held that a bad debt claim involving factual and legal analysis cannot be disallowed during section 143(1) processing. Such issues must be examined through regular assessment proceedings, not summary adjustments.
The case revolved around treating bank deposits as unexplained income without following the statutory mandate of rejecting books of account. The Tribunal reaffirmed that compliance with section 145(3) is mandatory before estimation, and granted full relief to the assessee.
This case dealt with an addition confirmed without adequate opportunity of hearing. The Tribunal held that passing an order without considering filed replies is unsustainable, and directed a de novo assessment.
The ITAT held that reassessment was invalid where notices and orders showed shifting facts and no independent reasoning. Changing bases across stages reflected a casual approach that vitiated jurisdiction.
