ITAT ruled that denial of TDS credit due to a PAN mismatch between the deceased and the legal heir is unjustified. Once the income is taxed in the hands of the legal heir, the corresponding TDS credit must also be granted.
The ITAT Chennai held that additions under Section 153A cannot be made for completed assessments when no incriminating material is found during search. Additions based only on special audit findings were therefore quashed.
The case addressed whether tax authorities can issue notices for multiple years based on one satisfaction note. The tribunal ruled that each assessment year requires an independent satisfaction linking seized material.
The court analysed whether the reason account blocked falls within the scope of Section 138 of the Negotiable Instruments Act. It held that the provision applies only when dishonour is linked to insufficient funds or lack of arrangement.
Supreme Court held that section 66 of the Companies Act, 2013 doesn’t require mandatory obtaining or circulating of formal valuation report from an approved/registered valuer for reduction of share capital.
The Tribunal held that when an adjustment made in the CPC intimation is subsequently deleted in appeal, the scrutiny assessment relying on that adjustment cannot continue. The income was therefore restored to the amount originally declared by the assessee.
Despite disputes over agricultural income additions, the Tribunal focused on the legality of the proceedings. It held that issuing a notice to a deceased taxpayer is a substantive illegality and cannot be treated as a curable procedural defect. The assessment was quashed.
The tribunal considered whether inconsistent explanations alone justify treating cash deposits as unexplained income. It held that suspicion cannot replace evidence and additions require proper investigation.
The tribunal examined whether the reasons given for late filing of the appeal were sufficient. It ruled that routine administrative workload and grievance handling cannot explain a substantial delay.
The tribunal considered whether CPC could rely solely on the original tax audit report to make an adjustment. It held that corrections through revised reports and financial records must be examined before sustaining an addition.
