Income Tax : ITAT held that where sales are not disputed, entire purchases cannot be disallowed. Only 15% profit element was taxed, reinforcing...
Income Tax : The Tribunal quashed reassessment proceedings as they were based on a mere change of opinion without any fresh tangible material. ...
Income Tax : The issue involved levy of late fees on TDS returns processed before statutory amendment. The Tribunal held that absence of enabli...
Income Tax : The Tribunal held that valuation without giving the assessee an opportunity to object violates natural justice. It remanded the ma...
Income Tax : The Tribunal condoned delay due to reasonable cause and addressed valuation mismatch. It remanded the issue for DVO-based reassess...
The Tribunal deleted addition under Section 69C, holding that payments made by company on behalf of director were properly explained through ledger records and imprest arrangement.
The ruling highlights that mere failure to file return, without concealment or tax evasion, does not automatically attract Section 270A penalty. Bona fide explanation and TDS compliance protected the taxpayer.
ITAT upheld deletion of additions where assessment was framed under the wrong provision. Since the year fell within the block period of a non-searched person, Section 153C was mandatory.
ITAT ruled that reassessment made pursuant to a quashed Section 263 order has no legal basis. Subsequent additions cannot stand once the revision itself is annulled.
The Tribunal ruled that TDS credit can be granted even if not fully reflected in Form 26AS, subject to verification. The deductee should not be penalized for the deductor’s failure to deposit tax.
The Tribunal clarified that Goetze (India) does not bar appellate authorities from entertaining new claims. Where all facts are on record, the claim must be examined on merits.
The ruling reiterates that adjudication based on incorrect material vitiates the entire order. The matter was remanded to ensure proper consideration of facts specific to the assessee.
While deleting the interest disallowance on merits, the Tribunal remanded the brought-forward loss issue for limited verification. Other legal grounds were treated as academic.
The ruling clarifies that reopening for AY 2016–17 must comply with the correct sanctioning authority requirement. Non-compliance invalidates the notice and all consequential actions under the Act.
The Tribunal observed that when a foundational jurisdictional issue exists, dismissal on limitation without examining merits is unsustainable. The reassessment and all consequential penalties were accordingly quashed.
