The Tribunal ruled that Section 153C requires the AO of the other person to independently assess whether seized documents have a bearing on that person’s income. A mechanical satisfaction note based solely on another officer’s communication was held invalid.
Jaipur ITAT held that reassessment proceedings were invalid because the Assessing Officer mechanically relied on Investigation Wing information without conducting independent verification.
The Tribunal ruled that third-party WhatsApp messages and decoded chat entries lacked evidentiary value against the assessee without corroborative material. The Revenue failed to prove that any cash was actually paid over and above the registered sale consideration.
The Tribunal ruled that technical lapses in e-verification cannot override a taxpayer’s lawful entitlement to a refund. Once the delay was condoned and the return accepted, denial of the refund was held unjustified.
The Tribunal ruled that reopening proceedings cannot survive where the mandatory sanction under Section 151 is not obtained from the prescribed authority. The defect was held to be jurisdictional, rendering the notice invalid.
Delhi ITAT held that donations qualifying under Section 80G do not lose eligibility merely because they form part of Corporate Social Responsibility (CSR) expenditure.
The Tribunal ruled that addition of the entire amount of bogus purchases as unexplained expenditure was unwarranted in the facts of the case. It reaffirmed that only the estimated profit arising from such purchases should be brought to tax.
Delhi ITAT ruled that delayed deposit of employees’ PF/ESI contributions attracts disallowance under Section 36(1)(va). The decision reinforces that such adjustments are permissible during summary processing of returns.
The applicant sought clarification on the applicability of Notification No. 16/2021-Central Tax (Rate) and the related GST rate. The Maharashtra AAR allowed withdrawal of the application without examining the merits.
The Maharashtra AAR allowed withdrawal of an advance ruling application seeking clarity on whether GST should be charged at 12% or 18%. Since the application was voluntarily withdrawn, no decision was given on the applicable GST rate.
