CAAR refused to entertain the advance ruling application, holding that classification of roasted areca nuts under Heading 2008 had already been decided by the Madras High Court. The authority invoked the statutory bar under Section 28-I(2).
The Authority held that a car window guide rail is not a machine part under 8479 but a motor vehicle body component under 87082900, based on its sole and principal use.
ITAT Mumbai deleted ₹6.15 lakh penny stock LTCG addition, holding investigation report and abnormal price rise insufficient without direct evidence linking assessee to accommodation entries.
The assessees long-term capital gains claim was upheld as genuine. In absence of direct evidence linking the assessee to manipulation, the Section 68 addition was deleted.
ITAT Mumbai quashed reassessment beyond 3 years as escaped income was ₹37.76 lakh (<₹50 lakh) and approval u/s 151 was wrongly granted by PCIT, rendering notice u/s 148 void.
Reassessment based solely on investigation inputs about penny stocks was rejected. The Tribunal held that documented transactions through bank and demat accounts sufficiently explained the investment source.
The Tribunal ruled that reopening beyond three years requires approval from higher specified authorities under Section 151. Since approval was taken from an incorrect authority, the reassessment was declared void.
The Tribunal observed that the assessee discharged its burden under Section 68 by filing confirmations, financials, and banking records of the lender. In absence of contrary evidence, the onus shifted to the Revenue. The addition was rightly deleted.
ITAT Mumbai observed that additions based solely on estimation do not establish concealment of income. Consequently, penalty under Section 271(1)(c) was deleted for both assessment years.
The Tribunal held that reassessment cannot survive when the final addition differs from the reasons recorded. Treating dividend as unexplained cash credit was beyond the scope of reopening.
