ITAT Pune held that the reassessment proceedings were invalid because the notice under Section 148 was approved by the Principal Commissioner instead of the authority prescribed under Section 151(ii). The reassessment order was declared void ab initio.
ITAT Pune held that reassessment proceedings were invalid because the approval under Section 151 was granted by the Principal Commissioner instead of the competent authority prescribed by law. The notice under Section 148 and the order under Section 148A(d) were quashed.
The ITAT Pune upheld the deduction under Section 10AA after finding that the Assessing Officer had not established that the SEZ units were formed by splitting up or reconstruction of an existing business. It followed earlier decisions in the assessee’s own case.
The ITAT Pune held that deletion of the addition was premature as the source of cash payments reflected in seized diaries had not been properly examined. It remanded the matter to the CIT(A) for fresh verification.
The Tribunal held that Rule 11UA gives the assessee the exclusive option to choose the valuation method for unquoted shares. While the AO may examine the DCF valuation, he cannot discard it and adopt the NAV method on his own.
The Tribunal held that contradictory third-party statements and unverified allegations cannot form the sole basis for taxing alleged on-money transactions. The ruling reiterates that suspicion cannot replace legally admissible evidence.
The ITAT held that an untested third-party statement, without supporting evidence or cross-examination, cannot form the sole basis for imposing penalty under Section 271D. It deleted the penalty after finding the Revenue failed to establish the alleged cash loan.
The ITAT held that Section 263 cannot be invoked where the Assessing Officer has made necessary inquiries and adopted a plausible view. It quashed the revision order after finding no lack of investigation into the related-party transaction.
The ITAT held that BSNL employees are entitled to full exemption under Section 10(10B) for compensation received under the 2019 VRS scheme. The Tribunal rejected the view that exemption should be restricted to ₹5 lakh under Section 10(10C).
The ITAT ruled that approval from the Principal Chief Commissioner/Chief Commissioner is mandatory for reopening assessments beyond three years. Since approval was obtained from an incorrect authority, the reassessment was declared void and the addition was deleted.
