The Tribunal examined whether revision under section 263 could survive when the show-cause notice was issued to an entity that had already ceased to exist due to amalgamation. It held that proceedings against a non-existent entity are void ab initio, rendering the revision order invalid.
The ruling clarified that the Finance Act, 2021 amendment applies only from AY 2022–23. For earlier years, exemption cannot be denied by treating the amendment as retrospective.
The dispute concerned denial of exemption due to belated filing of Form-10B. ITAT held the delay was not fatal and directed fresh consideration in light of the CBDT circular.
The issue was whether bank credits already offered as income in an HUF’s return could again be taxed in the individual’s hands. ITAT held that double taxation is impermissible and directed the AO to verify HUF records before making any addition.
Additions were made solely because the trust failed to submit details during assessment and appeal. ITAT set aside the assessments for fresh adjudication, stressing that substantive claims should be decided on merits rather than procedural lapses.
ITAT held that Section 153C cannot be invoked where the satisfaction/hand-over date is after 01.04.2021, quashing multiple assessments framed thereafter. The ruling follows the Madras High Court and reinforces Section 153C(3)’s statutory bar.
The Tribunal ruled that dismissing appeals in limine without examining reasons for delay was improper. It restored the matters for fresh consideration, stressing that procedural lapses should not defeat substantive justice.
The Tribunal held that post–Finance Act, 2024, an 80G application can be filed any time after commencement of activities. Rejection solely for delay was set aside and the application was restored for fresh consideration.
The ruling found that the authorities failed to examine party-wise payment limits before disallowing expenses for alleged TDS default. Key takeaway: threshold verification is essential before invoking section 40(a)(ia).
The ruling declares reassessment void where notices were not issued through the faceless mechanism post-29.03.2022. Lesson: non-compliance with section 151A vitiates reopening.
