The issue was whether the appellate authority could delete a large unexplained investment without following Rule 46A. The Tribunal held that bypassing mandatory procedure invalidates the relief, and the matter must be re-examined.
The issue was reopening beyond four years after a completed scrutiny assessment. The Tribunal held the reassessment invalid as there was no finding of failure to disclose material facts, a mandatory precondition under the proviso to section 147.
The issue was whether the appellate authority could enhance income by adding entire purchases when the AO had only made a small commission addition. The Tribunal held that such enhancement, without fresh material and beyond the subject matter of appeal, is illegal.
The Tribunal ruled that absence of formal registers or third-party bills does not automatically make expenses bogus. Additions based purely on estimates, without proof of inflation, are arbitrary and unsustainable.
The ITAT held that reassessment initiated in July 2022 for AY 2015-16 was barred by limitation. The ruling confirms that expired cases cannot be revived under the post-2021 reassessment framework.
ITAT found the recorded reasons vague and non-specific, failing to even identify the nature of alleged escapement. Such mechanical reasons render the notice under section 148 void ab initio.
The Tribunal condoned an extraordinary 2315-day delay, noting that the disallowance arose from a return-filing error and not lack of application of income. The matter was restored for fresh adjudication on merits.
The AO invoked Explanation 1(v) to section 153 to justify delay. The Tribunal clarified that an invalid 142A reference gives no such protection, rendering the order time-barred.
Protective addition was sustained despite completion of substantive assessment. ITAT clarified that protective assessment cannot survive after ownership and taxability are conclusively determined.
The assessee produced full details of the share subscriber, including financials and bank statements. ITAT held that after primary onus is discharged, the burden shifts to the Department, which was not met.
