ITAT held that the Assessing Officer failed to record proper satisfaction linking seized material to the assessee’s income. Consequently, proceedings under Section 153C were quashed.
The ITAT ruled that dismissing an appeal solely for non-compliance is contrary to law. The appellate authority is obligated to frame issues and pass a reasoned order on each ground raised.
The AO compared per-location payments to different vendors to allege excessiveness. The Tribunal held that such comparisons lack statutory backing when parties are unrelated and services differ in nature and complexity.
ITAT held that cash deposits during demonetization were explained as business sales declared under Section 44AD. Without disproving turnover, addition under Section 69A was unsustainable.
The AO completed assessment under Section 144 after alleged non-compliance, but failed to prove valid service of notice under Section 148. The Tribunal ruled that absence of jurisdiction renders the entire proceedings null.
The High Court held that reassessment cannot be based on grounds not mentioned in the original Section 148A notice. Since no income had escaped assessment, the reopening was quashed.
The PCIT questioned deduction under Section 80JJAA and CSR expenses but failed to record specific findings. The Tribunal held that absence of independent verification and reasoning renders the Section 263 order invalid.
Registration was cancelled over doubts about a large NRI donation. The Tribunal held that receipt of donation alone does not constitute a specified violation without evidence of misuse or non-genuine activities.
The Court ruled that provisional attachment under Section 83(1) cannot continue beyond one year as per Section 83(2). The attachment order was held to have lapsed by operation of law.
The Tribunal held that reopening beyond three years is impermissible where alleged escaped income is below ₹50 lakh. Since the notice violated Section 151, the reassessment was quashed.
