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 held that despite repeated notices, interests of justice required another opportunity. The case was remanded for fresh adjudication with costs imposed for prior non-cooperation.
The Tribunal held that for an unabated assessment year, additions under Section 153A must be based on incriminating material found during search. Since no such material linked to the loan was found, the Section 68 addition was deleted.
The addition was based on suspicion arising from third-party misconduct. The Tribunal reiterated that income tax additions cannot rest on presumptions alone.
The assessment relied on investigation reports without examining the alleged entry provider. The Tribunal held that cross-verification is essential before sustaining additions under section 68.
The assessee claimed that cash deposits belonged to company debtors and past savings, which were not examined earlier. The Tribunal restored the matter to the AO for re-verification in the interest of justice.
The case concerned denial of deduction citing dealings with associate members. The Tribunal followed Supreme Court precedent and directed the AO to verify member status and society bye-laws before deciding eligibility.
The Tribunal held that no interest disallowance can be made when ample interest-free funds are available. The key takeaway is that diversion cannot be presumed without establishing a nexus with borrowed funds.
The Tribunal held that issuing a Section 143(2) notice is compulsory once a return is filed under Section 148. Absence of such notice vitiates jurisdiction and nullifies the reassessment.
The Tribunal held that reassessment proceedings initiated after the statutory limitation period were invalid. Following the Supreme Courts ruling on reassessment timelines, the entire reopening and resulting additions were quashed.
The Tribunal held that reassessment notices issued by the jurisdictional officer violated the mandatory faceless regime under Sections 144B and 151A. Non-compliance with the prescribed faceless procedure renders the entire reassessment void ab initio.
