ITAT Surat held reassessment invalid where notice u/s 148, though dated 31-03-2021, was issued on 01-04-2021 without following s.148A procedure; entire reassessment quashed.
The case confirms that co-operative societies can claim Section 80P(2)(d) deduction on interest earned from co-operative banks. The appeal was allowed due to clear judicial precedent supporting the claim.
The addition was struck down as income was taxed before execution of sale deeds. Advances shown as liabilities were correctly offered to tax only when ownership passed to buyers.
The issue was denial of appellate remedy despite income being below taxable limits. The Tribunal ruled that appeals must be admitted and decided on merits in such cases.
The issue was whether a reassessment notice issued after the limitation period is valid. The Tribunal held that a notice issued beyond the prescribed time is void, nullifying the entire reassessment.
The issue was whether DVO-based valuation could inflate long-term capital gains for a co-owner. The Tribunal held that once co-owner relief applies, the DVO-based addition cannot survive.
The issue was whether an appeal can be dismissed outright for non-payment of advance tax. The Tribunal held that appellate authorities must first examine if advance tax was actually payable before rejecting the appeal.
The Tribunal deleted a cash credit addition after finding that temporary family deposits were fully explained. The ruling confirms that genuine, short-term deposits cannot be taxed without contrary evidence.
The Tribunal found that the first appellate authority decided the case without proper hearing and remanded the issue of section 54F deduction for fresh examination of additional evidence.
The Tribunal held that an appeal should not be rejected merely due to long delay when sufficient cause is shown. It ruled that technicalities cannot defeat substantial justice and restored the matter for decision on merits.
