The case examined whether vague information justified reassessment proceedings. The Tribunal ruled that absence of concrete material and nexus to escapement makes reopening without jurisdiction and liable to be quashed.
ITAT Chennai held that reassessment notice under section 148 of the Income Tax Act issued with approval of the Member of CBDT instead of Pr. CCIT is void and invalid. Accordingly, order passed under section 147 is without legal standing and hence quashed.
ITAT Chennai held that section 197(b) of the Finance Act, 2016 cannot be invoked since Form 2 as contemplated under Income Declaration Scheme not served. Accordingly, addition u/s. 69A made in assessment u/s. 147 r.w.s. 144 liable to be deleted.
The Tribunal held that where income is offered to tax on receipt basis, TDS credit must be granted in the same year despite timing differences arising from accrual-based deduction by clients.
ITAT held that an old trust could not be denied five-year registration merely due to technical restrictions in the online filing system. Provisional registration was set aside and fresh processing was ordered.
The addition on shares contributed to a family trust was deleted as the trust was exclusively for the benefit of relatives. Section 56(2)(x) does not apply where the statutory exemption conditions are satisfied.
The ITAT held that when reassessment is annulled for jurisdictional defects under the faceless regime, the connected concealment penalty cannot stand.
The tribunal held that once penalty is imposed for non-maintenance of books, a second penalty for non-audit cannot be levied. Levy of section 271B was held to be impermissible double penalisation.
The Tribunal clarified that approval under section 153D is an administrative safeguard and need not contain elaborate reasoning. Allegations of mechanical approval fail without concrete evidence of non-application of mind.
The tribunal held that assessment under section 153C cannot be initiated without seized material belonging to or relating to the assessee. Third-party statements and assumptions, without incriminating evidence, were held insufficient to confer jurisdiction
