The ITAT Delhi held that the upload date of DRP directions on the ITBA portal must be considered for computing limitation under Section 144C(13). Since the final assessment order was passed beyond the prescribed period, the assessment was quashed as time-barred.
ITAT Delhi held that amounts received from encashment of bank guarantees could not be treated as taxable income where the assessee acted only as custodian of government money. The Tribunal followed earlier rulings in the assessee’s own case and dismissed the Revenue’s appeal.
The Tribunal held that notice under Section 148 was invalid as it was issued by an officer lacking jurisdiction. It relied on CBDT Instruction prescribing monetary limits. The ruling highlights strict adherence to jurisdictional norms.
The tribunal held that interest cannot be disallowed where advances to related parties are made for business purposes and out of own funds, emphasizing the principle of commercial expediency.
The Tribunal held that consistent investment history and documentary proof established genuineness of share transactions. Additions under Section 68 were deleted due to lack of contrary evidence.
The Tribunal held that challenges to appreciation of evidence amount to review, not rectification. It ruled that Section 254(2) permits only correction of apparent errors, leading to dismissal of the Revenue’s application.
The Tribunal held that long-term capital gains cannot be disallowed solely on investigation reports and assumptions. It found that documentary evidence and investment history supported genuineness, leading to deletion of additions under Section 68.
The case examined reassessment based on third-party information without independent application of mind. The Tribunal ruled that reliance on borrowed satisfaction invalidated the addition, leading to its deletion.
The case addressed the taxability of duty drawback income based on accounting method. The Tribunal ruled that taxing it on accrual basis was incorrect and ordered deletion of the addition.
The case dealt with disallowance of employee contributions deposited beyond statutory due dates. The Tribunal remanded the matter for fresh examination of how “due date” should be determined, emphasizing factual verification and legal interpretation.
