The Tribunal examined whether reassessment notices issued by a jurisdictional officer instead of a faceless authority were valid. It held such notices invalid, quashing the entire reassessment proceedings.
The Tribunal held that an unsigned agreement without corroboration cannot be treated as incriminating material. Proceedings under section 153C were declared invalid.
The Tribunal held that payments and delivery handled by the assessee’s PA indicated control over the transaction. The absence of evidence supporting the daughter’s role led to confirmation of addition.
The Tribunal held that a development agreement granting only a limited license for construction does not constitute transfer under section 2(47)(v). As no consideration was received, capital gains addition was deleted.
Reassessment proceedings was invalid for a notice issued beyond three years without the sanction of the prescribed higher authority as prior approval must mandatorily be obtained from the authorities specified under Section 151(ii) and approval by the Principal Commissioner was not valid in such cases.
The issue revolved around expansion of scrutiny from cash deposits to entire bank credits. The Tribunal ruled that such expansion without mandatory approval renders the assessment void and unsustainable.
The issue was whether deduction under Section 80P is allowed when return is filed late. ITAT held that post-2018 amendment, deduction is barred if return is not filed within the due date under Section 139(1).
The issue was incorrect computation of interest without reducing foreign tax relief. ITAT held that relief under sections 90/90A must be deducted before calculating interest under sections 234A, 234B, and 234C.
The Tribunal held that TDS credit must be granted in the year in which the related income is assessed, even if it is not reflected in Form 26AS. The case clarifies that timing differences by the deductor cannot deny rightful credit.
The case addresses whether third-party cultivation affects Section 54B eligibility. The Tribunal ruled that use of land for agriculture, even via villagers, satisfies legal conditions. The decision reinforces substance over form in proving agricultural use.
