High Court set aside reassessment proceedings after finding that the notice was based only on existing records, with no new material to justify reopening of the completed scrutiny assessment.
The appeal was dismissed solely on procedural grounds without hearing the assessee. The Tribunal held that the CIT(A) is duty-bound to decide appeals on merits after granting a proper opportunity.
The Tribunal examined whether Section 153A could be applied to the search year itself. It held that invoking Section 153A for the wrong assessment year was invalid, rendering the assessment void.
The Tribunal held that reopening after four years is invalid without alleging failure to disclose material facts. The reassessment was barred by the proviso to section 147.
The Tribunal held that rural agricultural land excluded from capital asset under Section 2(14) cannot be taxed under Section 56(2)(vii)(b). Addition based on stamp duty valuation was therefore deleted in full.
The Tribunal held that serving notices on an outdated email ID violates principles of natural justice. The assessment was set aside and the matter restored for fresh adjudication after proper service.
The authority ruled that carbon pultruded plates are not carbon fibre under the amended exemption notification and therefore cannot claim concessional duty as raw materials, clarifying the limited scope of the revised entry.
AAR Mumbai held that architecturally finished stainless steel wall panels retain the character of flat-rolled products and must be classified under Heading 7219, not as structural parts or miscellaneous articles.
The authority examined whether a plastic nozzle connector should be taxed as a general plastic article or as machinery parts. It held that exclusive and indispensable use in washing machines requires classification as a machine part under heading 8450.
The ITAT held that income addition based solely on Form 26AS differences cannot survive when books are audited and no defects are found.
