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The issue was whether reassessment beyond 3 years is valid when escaped income is below ₹50 lakh. The ruling held such notice invalid under Section 149, and the key takeaway is strict adherence to limitation rules.
ITAT held that reassessment initiated with approval from the wrong authority is invalid when issued beyond three years. The entire proceedings were quashed. The key takeaway is that proper sanction under Section 151 is mandatory.
ITAT held that estimating profit at 8% without considering records was excessive. It reduced the rate to 3% based on business realities. The key takeaway is that estimation must be reasonable and evidence-based.
ITAT held that a return filed under section 148 remains valid even if delayed. Failure to issue mandatory notice under section 143(2) makes reassessment void.
The case addressed whether a special audit can be ordered without establishing complexity or defects in accounts. The Court examined whether mechanical invocation of Section 142(2A) without proper justification is legally sustainable.
The Court ruled that the reassessment notice was invalid as it exceeded the statutory 10-year limit under Section 153A. It clarified that the search year must be included in computing the extended limitation period.
The Court held that reassessment proceedings are invalid if approval is obtained from an incorrect authority. It clarified that sanction must strictly comply with Section 151 based on elapsed time limits. The ruling reinforces jurisdictional safeguards in reassessment cases.
The Court held that reassessment based solely on an audit objection is invalid as it constitutes a change of opinion. It emphasized that previously examined issues cannot be reopened without new tangible material. The ruling reinforces limits on reassessment powers.
The issue was whether reassessment can survive when no addition is made on the stated reasons for reopening. The Tribunal held that such reassessment is invalid, and the AO cannot make unrelated additions.
ITAT held that reassessment without issuing notice under Section 143(2) is invalid, even if return was filed late. The ruling emphasizes that issuance of notice is mandatory and absence of it makes the assessment void.
