The issue concerned massive additions made in an ex-parte assessment due to alleged unexplained share transactions. The Tribunal held that such issues require proper factual verification and remanded the case for fresh adjudication.
The trust sought exemption by invoking later registration under section 12AA. The tribunal ruled that exemption cannot be granted retrospectively through section 154 when no assessment was pending on the registration date.
The assessee demonstrated that the ₹1.03 crore cash deposit arose from opening cash balance and collections from sundry debtors. The Tribunal held that the onus stood discharged and deleted the entire addition.
ITAT held that CPC cannot increase dividend income based on Schedule BP entries, restricting taxable dividend to the amount correctly disclosed in the return and upholding section 115BBDA exemption.
The Assessing Officer proceeded with reassessment after three years based solely on PCIT approval. The Tribunal emphasized that compliance with Section 151 is mandatory, and failure renders the notice under Section 148 void.
Reassessment was quashed as the statutory process under the faceless regime was not followed end-to-end by the same authority. Such jurisdictional inconsistency vitiates the entire proceedings.
The Tribunal held that reassessment initiated solely on a Revenue audit objection, without fresh tangible material, is invalid. Reopening beyond four years on the same facts examined earlier amounts to impermissible change of opinion.
Where income admitted in section 153C proceedings is accepted in assessment, penalty still requires strict compliance with section 270A. Absence of a specific misreporting charge defeats penalty levy.
The ITAT Chennai held a reassessment notice under section 148 invalid as it was issued after the statutory limitation expired, emphasizing strict compliance with time limits.
The Tribunal held that mere possession of cash during seizure does not establish ownership for section 69A. Where the source is explained and ownership lies elsewhere, addition in the carrier’s hands is unsustainable.
