The Tribunal examined whether a single satisfaction note could sustain reassessment proceedings for multiple years under section 153C. It held that a composite satisfaction is valid when based on common seized material spanning several assessment years.
The Tribunal held that inadvertent mistakes in filing Form 10AB cannot defeat a trust’s right to exemption. Registration was directed where objects and activities were never disputed.
The Tribunal held that a continuously maintained ledger found during search constituted reliable evidence. Additions for unexplained expenditure under section 69C were sustained based on corroborated diary entries.
The issue was whether a WhatsApp image from a third party could justify a cash addition. The Tribunal held the digital evidence inadmissible due to lack of lawful collection and chain of custody, deleting the addition.
The reassessment was annulled after the notice was found procedurally defective. The Tribunal affirmed that binding High Court precedent required issuance by a faceless AO.
The Tribunal held that once a Section 263 revision is set aside, the consequential assessment has no legal existence. All proceedings based on such assessment automatically collapse.
Penalties were imposed for cash transactions during the first year of business. The Tribunal found bona fide circumstances and no tax-evasion intent, granting relief under section 273B. The ruling underscores liberal interpretation of reasonable cause.
Holding Section 54F to be a beneficial provision, the Tribunal applied settled judicial principles to allow exemption where substantive conditions were met, directing deletion of the capital gains addition.
The reassessment was initiated beyond the permissible time frame. The Tribunal declared the entire proceedings void from inception. The key lesson is that jurisdictional defects render reassessments unenforceable.
The Tribunal held that reassessment fails when the show-cause notice is issued on an incorrect factual premise. Jurisdiction under section 147 collapses if the foundation under section 148A is flawed.
