ITAT held reassessment invalid as it was based on already examined facts without fresh material. The ruling reinforces that reopening on mere change of opinion is not permissible.
ITAT held that section 249(4) cannot be invoked where no taxable income arises in India. Appeals must be decided on merits rather than dismissed on technical grounds.
The Tribunal ruled that even temporary withdrawals by a shareholder can trigger deemed dividend under Section 2(22)(e). It held that duration or repayment does not negate taxability.
The ruling clarifies that unauthenticated digital chats and screenshots cannot form the sole basis of tax additions without proper verification and legal compliance.
The court held reassessment invalid where proceedings were based solely on unverified digital material from unrelated parties. It ruled that absence of a live nexus with income escapement makes reopening unsustainable.
The Tribunal ruled that failure to obtain prior approval for loans is only a procedural lapse. It directed reconsideration of 12A registration after acknowledging genuine charitable activities.
The Tribunal ruled that reassessment cannot be reopened on issues already examined earlier. It held that absence of fresh material and mere change of opinion renders reopening invalid.
ITAT Mumbai rules actuarial provisions for employee benefit schemes are allowable under Section 37(1) as ascertained liabilities, deletes major disallowances on expense provisions, limits TDS applicability to payment stage, and prevents double taxation of expenses.
ITAT Mumbai rules that Section 14A disallowance cannot exceed exempt income, directing AO to cap disallowance accordingly and delete excess addition, granting relief to assessee.
ITAT Mumbai holds reassessment invalid where approval under Section 151 was obtained from incorrect authority, ruling defect as jurisdictional and quashing notice under Section 148 and consequent proceedings.
