The Supreme Court ruled that limitation for revisional proceedings under Section 263 must be counted from the original assessment order where the issues are unrelated to reassessment proceedings. The Court dismissed the Revenue’s appeal as the revision order was held time-barred.
ITAT Hyderabad held that the reassessment notice issued for AY 2015-16 after 31.03.2022 was barred by limitation under the first proviso to Section 149 and therefore invalid.
The Karnataka High Court condoned a 60-day delay in filing a GST appeal and restored the matter for decision on merits. The Court relied on earlier decisions passed in similar circumstances.
Delhi ITAT Restricts Corporate Guarantee Fee to 0.30% After Finding Actual Interest Saving Was Only 0.60%; Holds TP Adjustment Must Reflect Real Benefit From Corporate Guarantee.
ITAT Mumbai upheld deletion of consultancy expenditure disallowance after finding that the Assessing Officer failed to produce cogent evidence showing that services were not rendered. The Tribunal held that suspicion and third-party allegations alone could not justify the addition.
ITAT Delhi deleted penalties imposed for alleged cash transactions after holding that the electronic evidence relied upon by the Revenue was inadmissible in law. The Tribunal observed that mandatory procedures relating to digital evidence handling and chain of custody were not properly followed.
ITAT Chandigarh deleted an addition made under Section 69 after finding that the Assessing Officer relied only on an Excel sheet entry without corroborative evidence. The Tribunal held that suspicion alone cannot justify an addition.
The case involved additions based on seized diaries, alleged cash sales, and estimated profits. The ITAT partly accepted the assessee’s arguments and directed adoption of a revised industry GP rate for computing taxable income.
The Allahabad High Court held that no pattern of unequal marking by different interview boards was established in the UPHJS 2016 recruitment process and dismissed the plea for moderation of marks.
The Supreme Court held that written statements filed after expiry of the mandatory 120-day period under the amended CPC cannot be taken on record in commercial suits. The ruling emphasizes strict compliance with timelines introduced by the Commercial Courts Act.
