The court held that revision under section 263 requires independent satisfaction by the PCIT. Acting merely on the Assessing Officer’s view renders the revision order invalid.
The issue was whether high-turnover companies can be compared with a smaller software service provider. The Tribunal held that companies with disproportionately large turnover must be excluded as they distort comparability due to scale advantages.
The case involved additions made solely on an Excel sheet and a third-party statement alleging cash payments. The Tribunal ruled that such unverified material, without independent evidence, cannot justify additions.
The issue was whether penalty applies when a bogus donation claim is withdrawn after detection. The Tribunal held that post-detection withdrawal is not voluntary, and penalty for misreporting was rightly imposed.
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 issue involved denial of LTCG exemption based on allegations of penny stock manipulation. The Tribunal held that without direct evidence or nexus, such additions cannot be sustained.
The case examined whether separate penalties under CGST and SGST were permissible. The Court ruled such imposition unjustified and restricted the penalty to ₹25,000.
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.
