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Income Tax : Tribunal observed that the Assessing Officer failed to establish any mismatch in stock, sales, or accounting records before making...
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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 approval under Section 151 was invalid as the PCIT merely noted As per Annexure without independent satisfaction. The reassessment under Section 147 was declared void ab initio.
Bombay High Court held that notice u/s. 148 of the Income Tax Act issued after obtaining sanction under section 151 from the non-competent authority is invalid and not sustainable in law. Accordingly, notice is liable to be quashed and petition is allowed.
The Tribunal found no infirmity in the CIT(A)s detailed order deleting additions based on proper verification of evidence. All grounds raised by Revenue were rejected, and cross-objection became infructuous.
ITAT Delhi held that notice under Section 148 issued before obtaining mandatory approval under Section 151 is invalid. Since sanction was granted after issuance of notice, the reassessment was declared void ab initio.
The Tribunal confirmed the jurisdictional validity of reassessment based on new information. However, the addition was restored to ensure compliance with principles of natural justice and Section 250(6).
The Tribunal ruled that failure to examine whether payees discharged tax liability vitiates proceedings under Section 201. The case was sent back to the AO to verify compliance and re-decide the issue.
ITAT ruled that reliance on statements without offering cross-examination and without supporting evidence violates principles of natural justice. Additions under Sections 69A and 153C were set aside.
The Tribunal held that failure to indicate the precise charge in a Section 274 notice renders penalty proceedings unsustainable. Following jurisdictional High Court rulings, the penalty was set aside.
The Tribunal emphasized that the test under Section 57(iii) is one of purpose and connection. As the assessee demonstrated reasonable nexus between borrowings and interest income, the deduction was upheld.
Relying on Supreme Court and Bombay High Court rulings, the Tribunal ruled that sanction by an incorrect authority vitiates jurisdiction. The reassessment proceedings were set aside for non-compliance with Section 151.
