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Income Tax : ITAT Mumbai deleted a Section 69 addition after finding documentary evidence established joint ownership, source of funds, and ear...
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Income Tax : ITAT Surat held that delayed filing of Form 10B is a procedural lapse and remanded the matter after directing the AO to consider t...
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Income Tax : Instruction No.1/2015 Clarification regarding applicability of section 143(1D) of the Income-tax Act, 1961- Vide Finance Act, 2012...
The ITAT held that Section 40(a)(ia) could not be invoked where the assessee had not made the rent payments referred to in the tax audit report. The addition was traced to an inadvertent reporting error by the auditor.
The Tribunal held that the reassessment order was invalid because it was passed within four weeks of disposing of the assessee’s objections to reopening. Following Bombay High Court precedents, the reassessment proceedings were quashed.
Assessments arising from searches conducted after 01.04.2021 must strictly comply with the reassessment framework under sections 147 and 148. Failure to adhere to statutory jurisdictional requirements, including mandatory approvals and satisfaction for use of third-party material, rendered the entire assessment void.
The ITAT ruled that an assessment made after the assessees death was not void ab initio where jurisdiction had already been validly assumed before death. The matter was remanded for passing a fresh order in the name of the legal representative.
Tribunal held that the differential amount between the levy price of sugar and the concessional price at which it was sold by a co-operative factory to its members and non-members constitutes an unallowable appropriation of profit to be added to business income, or a valid business practice could not be decided without examining the factual parameters mandated by the Supreme Court in Krishna Sahakari Karkhana Ltd.
The Tribunal ruled that the Assessing Officer wrongly invoked Section 154 to withdraw deduction on interest income from co-operative banks. Since the issue is subject to differing judicial interpretations, it falls outside the scope of rectification.
The Tribunal criticized the Assessing Officer for taking a contrary stand in later years after allowing the same deduction on identical facts in an earlier assessment. It held that such inconsistent treatment without distinguishing facts was unsustainable.
The Tribunal found that the reasons recorded for reopening contained incorrect figures and unsupported assumptions. It held that the reassessment proceedings were invalid and void ab initio due to lack of proper application of mind.
ITAT Delhi held that the PCIT exceeded jurisdiction by introducing issues not mentioned in the Section 263 show-cause notice. The revision order was quashed for travelling beyond the scope of the proceedings.
The Tribunal held that documents relating to the assessee were found during the search of another person. It ruled that proceedings could only be initiated under Section 153C, making the reassessment under Section 148 invalid.
