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The case of assessee-company was that originally the assessment was transferred to the National e-Assessment Centre and notices were issued by the National e-Assessment Centre, New Delhi.
Assessee-bank had calculated tax for the relevant assessment year based on both book profits under Section 115JB at Rs.604,86,39,540 and normal provisions at Rs.1153,29,54,493.
ITAT Ahmedabad held that the revisionary jurisdiction under section 263 cannot be exercised to widen the scope of the original assessment beyond the specific reasons recorded for reopening the assessment.
ITAT Ahmedabad held that additional evidence reconciling the discrepancy in receipts as per Form No. 26AS and books of accounts were not submitted before AO or CIT(A). Accordingly, matter send back to CIT(A).
ITAT Hyderabad held that the Tribunal has no power to recall/review its own orders in terms of scope and power of Tribunal for rectification of order u/s. 254(2) of the Income Tax Act.
Delhi High Court held that initiation of reassessment under section 147/148 of the Income Tax Act merely on the basis of DVO report without application of mind by the AO is unsustainable and liable to be quashed.
ITAT Delhi held that holding company can adopt FMV of the asset held by subsidiary company and rework value of investment held in subsidiary company, such approach is not contract to section 56(2)(viib) of the Income Tax Act.
ITAT Mumbai held that when part refund is granted it should be first adjusted towards outstanding interest and then against the tax payable. Interest u/s. 244A of the Income Tax Act directed to be calculated accordingly.
ITAT Ahmedabad held that imposition of penalty u/s. 271(1)(c) of the Income Tax Act justified as deduction was claimed u/s. 54EC and 54F of the Income Tax Act by furnishing inaccurate particulars.
ITAT Mumbai held that accommodation entries in the nature of bogus unsecured loans is liable to be added as unexplained under section 68 of the Income Tax Act. Accordingly, addition u/s. 68 confirmed.
