The ITAT quashed assessments under Section 153A due to ex-parte orders, mechanical Section 153D approvals, and failure to give the assessee an opportunity to be heard, emphasizing the importance of natural justice in tax proceedings.
The Tribunal held that short notice and lack of opportunity violated principles of natural justice in rejecting 80G registration. The CIT(E) is directed to allow the assessee to explain the Trust’s objectives. The appeal was allowed for statistical purposes, ensuring fair adjudication.
ITAT Ahmedabad remands the matter after persistent non-compliance, directing the assessee to prove the source of cash payments against credit-card expenses. A cost of ₹5,000 to PMNRF is imposed as a condition for fresh examination.
Tribunal confirms that co-operative societies’ operational expenditures have business nexus with interest income; Section 57 deduction of Rs.62.57 lakh allowed.
The Tribunal held that once the High Court had already quashed the original assessment for violating the IBC resolution plan, the PCIT’s section 263 revision could not survive. Since a revision must rest on a valid assessment order, the entire 263 action became void. The appeals were allowed and the revision orders were cancelled.
The Tribunal held that cash deposits were fully explained through matching earlier withdrawals. The addition of ₹15 lakh was removed as the source of funds was satisfactorily proven.
The Tribunal invalidated an assessment passed without awaiting the Departmental Valuation Officer report, holding that provisional assessments violate section 50C(2) and 143(3). The rectification under section 154 based on later material was also impermissible.
ITAT set aside CIT(E) orders denying 12AB registration, holding that section 13(1)(b) cannot be invoked at registration stage; charitable intent and activities must be examined independently.
The ITAT Ahmedabad quashed PCIT’s revisionary orders, holding that Section 263 powers cannot be used when the AO has made thorough enquiries. Revision requires demonstrable error prejudicial to revenue, not mere differences of opinion.
The Tribunal held that Section 263 cannot be invoked when the PCIT himself does not conduct the verification he insists was missing. It reaffirms that revision requires demonstrated lack of inquiry, not assumptions.
