Assessments arising from searches conducted after 01.04.2021 must strictly comply with the reassessment framework under sections 147 and 148. Failure to adhere to statutory jurisdictional requirements, including mandatory approvals and satisfaction for use of third-party material, rendered the entire assessment void.
The Tribunal held that penalty under Section 272A(1)(d) could not survive once the Assessing Officer completed assessment under Section 143(3) after accepting the assessee’s explanations and returned income.
The Jodhpur ITAT condoned a 30-day delay in filing an income tax appeal after holding that the delay fell within the Supreme Court’s COVID-19 limitation exemption period. The matter was remanded to the CIT(A) for fresh adjudication.
The Jodhpur ITAT held that penalty under Section 272A(1)(d) could not survive where the Assessing Officer completed scrutiny assessment under Section 143(3) after considering replies and documents furnished later by the assessee.
The Tribunal held that absence of commenced activities is not a valid ground to deny registration where objects are charitable and proposed activities align with them.
ITAT held that CPC cannot deny charitable exemption under section 11 through section 143(1) adjustment without issuing prior intimation. The matter was restored to the AO for fresh examination after due opportunity.
The Tribunal held that a short delay caused by hospitalisation must be condoned when supported by evidence. Procedural lapses cannot defeat substantive justice.
The case addressed whether an authority can reject registration before completion of parallel statutory processes. The Tribunal held that hurried rejection was unjustified and directed de novo adjudication.
The addition under Section 69 was remanded as the assessee claimed the source through rotation of funds. The Assessing Officer must now verify the fund flow after granting proper hearing.
The lower authorities confirmed an addition without considering permissible valuation variation. The Tribunal held that ignoring the 10% tolerance under section 50C renders the addition invalid.
