Construction, fit-out, and IT installation costs capitalised in fixed assets were held genuine. The Tribunal emphasized substance of records over suspicion based on third-party allegations.
The Tribunal held that no TDS demand can survive where tax was duly deposited and PAN became operative within the CBDT-prescribed timeline. Deductors are entitled to relief under the beneficial 2024 CBDT circular.
The Tribunal held that reassessment initiated solely on the basis of an audit objection, without any independent application of mind, is invalid. Such reopening lacks the mandatory reason to believe and cannot sustain in law.
Sales already offered to tax cannot be added again under section 68. With stock movement evidenced and books not rejected, treating recorded turnover as unexplained cash credit was held unsustainable.
The Tribunal held that estimating profit at 20% of turnover in a milk trading business was arbitrary and unsupported by industry realities. It restricted the gross profit rate to 5%, recognising wastage, spoilage, and thin margins typical to the trade.
The Tribunal held that revision under section 263 was invalid where the MAT adjustment arose mechanically from a transition amount already examined in an earlier year, and no fresh error was shown.
The Court held that the extended limitation period under Section 74 was prima facie invoked only for specific ITC allegations and not for all demands. Recovery was stayed as most claims appeared to fall outside the extended period.
The Tribunal held that remanding an assessment under the amended section 251(1)(a) is legally valid. The key takeaway is that appellate remand powers now have clear statutory backing.
The High Court set aside a GST demand where no show cause notice or hearing opportunity was given. The ruling reiterates that adjudication without due notice violates natural justice.
The court held that ITC disallowance under Section 16(4) became unsustainable due to retrospective statutory amendment and remitted remaining issues for fresh adjudication with conditional pre-deposit.
