The case involved a penalty for alleged non-disclosure of a foreign bank account. The Tribunal held that ambiguity regarding linked currency accounts required fresh verification before sustaining the penalty.
The issue was whether an assessment under the Black Money Act can survive once the foundational notice is held invalid. The Tribunal held that an invalid Section 10(1) notice nullifies all subsequent proceedings.
The Tribunal held that advertising and sales promotion expenses incurred on dealers and third parties cannot be treated as fringe benefits. The key takeaway is that FBT applies only where expenditure amounts to consideration for employment.
The Tribunal held that revision under section 263 was invalid where the MAT adjustment arose mechanically from a transition amount already examined in an earlier year, and no fresh error was shown.
The AO treated loan substitution via group restructuring as an accommodation entry. ITAT ruled that repayment by a holding company backed by bank trails and confirmations cannot be taxed as unexplained credit.
ITAT Mumbai quashed reassessment for AY 2017-18 as notice issued after three years lacked mandatory sanction under Section 151(ii), holding approval by Pr.CIT insufficient under post-2021 law.
The case involved share capital raised at a high premium based on unexecuted projects and circular fund routing. ITAT held that failure to prove creditworthiness and genuineness justified addition under Section 68.
The Tribunal considered whether a penalty can stand independently while the core addition is pending fresh adjudication. It ruled that penalty cannot precede final determination of income and must be deleted at this stage.
The Tribunal assessed compliance with revised reassessment provisions post Finance Act, 2021. It ruled that sanction by a lower authority after three years is non-est in law, leading to quashing of the reassessment.
CIT(A) remanded a completed scrutiny assessment even after the AO accepted additional evidence in remand. ITAT ruled this exceeded statutory powers and restored the case to CIT(A) for a merits-based decision.
