Interpreting Sections 21 and 22 together, the Court held that heirs inheriting an estate must maintain statutory dependants. A widowed daughter-in-law qualifies even if she did not receive a share in the estate. The decision clarifies obligations of successors.
The Tribunal clarified that expenditure disallowances do not qualify as assets under section 149(1). Without asset-based escaped income, reopening beyond three years is barred. This offers strong protection against belated reassessments.
The Tribunal held that interest from bank fixed deposits lacked a direct nexus with credit facilities. Deduction under Section 80P was denied as investment income dominated.
The Tribunal held that reopening based solely on third-party information without independent application of mind is invalid. Income escaping assessment must be based on the Assessing Officer’s own reason to believe.
The High Court upheld rejection of a limitation plea raised only at the hearing stage. It held that without supporting facts on record, such a plea cannot be entertained.
The Tribunal held that no commission income can arise from circular transactions within group entities. Additions based on estimated commission for such intra-group sales were deleted.
The High Court held that the “relevant period” under Rule 89(4) must be applied uniformly for ITC, turnover, and adjusted turnover. Selective interpretation for refund computation was rejected.
The High Court held that Notifications extending GST limitation were vitiated and illegal. As a result, the assessment order based on them was set aside and remanded for fresh consideration.
The Court held that once copies of DRT proceedings are supplied as un-relied documents, the accused cannot compel the investigating agency to produce original tribunal records.
The Tribunal held that an intimation making large additions without giving adequate opportunity violates principles of natural justice. The matter was remanded for fresh adjudication.
