The Tribunal held that once CPC allowed the 80JJAA deduction through a subsequent Section 154 order, the earlier rectification appeal no longer survived. The appeal was dismissed as academic, with a clarification that no extra deduction beyond what CPC allowed could be granted.
ITAT held that penalty under Section 271(1)(c) cannot survive when the underlying addition is remanded, directing the AO to re-decide the penalty after the quantum order is finalized.
The Tribunal set aside the ex parte dismissal of the AY 2018-19 appeal, restoring the matter to CIT(A) for merits-based hearing. The assessee was allowed to present evidence regarding ₹3.74 crore unexplained investment and estimated profits.
The Tribunal upheld CIT(A)’s deletion of ₹2.81 crore transfer pricing adjustment, ruling that selected comparables were functionally and financially dissimilar. PSM was maintained as the Most Appropriate Method, ensuring fair benchmarking of international transactions.
ITAT rules that an additional 54B claim omitted in the original return cannot be mechanically rejected. AO must examine the claim on merits, verifying capital gains utilisation and statutory conditions.
ITAT Ahmedabad set aside the ex-parte CIT(A) order confirming ₹36.3 lakh addition for advance rent. The matter was restored to AO for de-novo adjudication, and the assessee was granted full opportunity to present evidence, with a ₹5,000 cost imposed.
ITAT Ahmedabad set aside the ex-parte CIT(A) order where notices were sent to a wrong email ID, causing non-receipt by the assessee. The matter, including Sec.69A addition and denial of cross-examination, was remitted to CIT(A) for fresh adjudication on merits.
ITAT Ahmedabad held that speculative intraday trades are genuine and not accommodation entries. Additions under Section 68 totaling ₹1.25 crore and ₹1.53 lakh were deleted due to lack of foundational facts and proper inquiry.
ITAT Ahmedabad held that reassessment under Section 147 cannot be based on vague or unverified information; specific transactions must be identified to justify additions.
The ITAT determined that the tax department failed to adhere to the statutory deadline for issuing a Section 148 notice, making the reassessment jurisdiction invalid from the start. The ruling confirms that strict adherence to the extended limitation period is mandatory, and failure to comply results in the entire reassessment being quashed.
