The Tribunal held that additions based solely on third-party statements and seized digital data cannot survive without allowing cross-examination. The matter was remanded for fresh adjudication after granting due opportunity to the assessee.
The Tribunal ruled that additions under section 69 cannot exceed the amount actually invested during the relevant year. Where most payments were loan-funded, only the year-specific payment required examination.
ITAT Delhi quashed reassessment issued beyond three years where alleged escapement was only ₹35 lakh. Section 149 bars reopening unless the ₹50-lakh threshold is satisfied.
ITAT Chennai held that loss on sale of shares must be treated as long-term capital loss. Wrong accounting classification cannot convert it into a disallowable expense.
The Tribunal held that an assessment framed without issuing a compulsory notice under section 153C lacks jurisdiction. Even seized material cannot cure this foundational defect, rendering the order void ab initio.
The Tribunal held that reassessment is invalid where the mandatory notice under Section 143(2) is issued beyond the prescribed time limit. Absence of a valid and timely notice strikes at the very jurisdiction of the Assessing Officer.
ITAT Delhi held that reassessment based on mechanical approval is invalid in law. Sanction must reflect independent application of mind by the approving authority.
The issue was whether stamp duty value as on registration could override actual consideration received earlier. The Tribunal held that section 50C is a machinery provision and cannot be applied mechanically to post-transfer market increases.
The Tribunal held that incorrect selection of a clause in Form 10AB is a curable clerical mistake. Registration applications cannot be rejected without examining the trust’s objects and activities on merits.
ITAT Delhi ruled that expiry of limitation only bars recovery and does not extinguish the debt itself. Outstanding loans remain liabilities unless expressly waived by lenders.
