The Tribunal held that reopening based on unverified Investigation Wing inputs, factual inconsistencies, and no direct nexus to the assessee’s transactions is invalid. Mechanical reproduction of information cannot sustain reassessment.
Rejecting contradictory treatment, the Tribunal ruled that the Revenue cannot approbate and reprobate by accepting the lender’s scrutiny while taxing the borrower under section 68. The addition was therefore deleted.
The issue was whether Section 153C proceedings for seven years could rest on a single satisfaction note. ITAT held that absence of year-wise satisfaction vitiates jurisdiction, quashing all assessments.
The Tribunal confirmed that post-2021 reassessment notices must strictly comply with amended section 151. Non-compliance with the specified approving authority deprives the Assessing Officer of jurisdiction.
Applying the test of human probabilities, the Tribunal ruled that unexplained abnormal sales could not be fully accepted. At the same time, absence of book defects warranted estimation instead of outright section 68 taxation.
The Tribunal held that a one-day delay in depositing employees’ PF caused by proven payment gateway failure constitutes impossibility of performance. Genuine attempts and evidence justified allowing the deduction despite strict timelines.
The Tribunal ruled that CIT(A) exceeded jurisdiction by remanding a completed scrutiny assessment. The decision clarifies that remand powers apply only to Section 144 assessments, not regular ones.
The issue was whether further disallowance could be made after a suo motu 30% disallowance under section 40(a)(ia). The Tribunal ruled that any additional adjustment amounts to double disallowance and is impermissible.
The issue was whether a regular assessment could survive once section 153C was triggered for a non-searched person. The Tribunal ruled that pending scrutiny abates, making an assessment under section 143(3) void from inception.
The issue was whether reassessment can stand on an unsigned notice under Section 148. ITAT held that an unsigned notice confers no jurisdiction, rendering the reassessment void ab initio.
