The Tribunal held that reopening based solely on third-party information without independent application of mind is invalid. Income escaping assessment must be based on the Assessing Officer’s own reason to believe.
Since the statutory notice under section 143(2) was issued by a non-jurisdictional officer, the assessment collapsed. The ruling affirms that valid notice by the competent authority is a sine qua non.
The Tribunal ruled that additions made on issues beyond limited scrutiny were without authority since proper conversion to complete scrutiny was not followed. The key takeaway is that violating CBDT instructions renders the entire assessment void.
The Tribunal ruled that reassessment actions taken by the faceless assessment centre before the notified date were without authority. The final assessment order was therefore held invalid.
The issue was whether revision could stand on incorrect factual assumptions. ITAT held that misreading records makes the revision invalid, reaffirming that Section 263 needs real errors.
The issue was whether a reassessment notice issued after the surviving limitation period was valid. The Tribunal held the notice time-barred in light of the Supreme Court ruling, rendering the entire reassessment invalid.
The AO accepted documents but still made an addition without pointing out defects. The Tribunal ruled that section 68 requires adverse findings, not assumptions.
The Tribunal upheld reassessment based on Investigation Wing material alleging accommodation entries. It ruled that such tangible inputs justified reopening despite a completed scrutiny assessment.
The Tribunal held that delayed filing of an audit report cannot justify wholesale disallowance of expenses at the CPC processing stage. Such action falls outside the limited scope of Section 143(1) adjustments.
The issue was whether an appeal could be dismissed solely for delay without examining merits. The Tribunal held that where delay is bona fide, technical rejection is improper and the matter must be decided on merits.
