The Tribunal held that assumption of jurisdiction under Section 153C was invalid due to a defective and consolidated satisfaction note. As the mandatory requirement of year-wise satisfaction was not met, the entire assessment was quashed.
ITAT Mumbai held that transfer pricing addition made in respect of Letter of Comfort rightly deleted since Letter of Comfort didn’t constitute an International Transaction. Accordingly, order passed by CIT(A) upheld to that extent.
The Tribunal held that acceptance of returned income without examining material indicating possible unaccounted cash investment amounts to lack of inquiry. Section 263 revision was therefore lawfully sustained.
ITAT Mumbai held that disallowance made under section 14A of the Income Tax Act added to Book Profits for computing taxes under section 115JB Income Tax Act deserved to be deleted.
ITAT ruled that once cash sales are recorded in audited books and accepted by the AO, taxing the same deposits again would result in double addition. The deletion of ₹1.54 crore was upheld.
The Tribunal held that reassessment beyond four years is invalid where the assessee had fully disclosed material facts during original scrutiny. In absence of failure to disclose, reopening under Section 147 was quashed.
The ITAT held that approval under Section 151 was invalid as the PCIT merely noted As per Annexure without independent satisfaction. The reassessment under Section 147 was declared void ab initio.
CESTAT Chandigarh held that the demand of service tax on adda-fees under the category of ‘business support services’ is not sustainable in law and is liable to be set aside. Accordingly, order is liable to be set aside and appeals are allowed.
The Tribunal held that reassessment proceedings fail when the Assessing Officer abandons the issue forming the basis of reopening. In such cases, other additions cannot be made without issuing a fresh notice under Section 148.
Bombay High Court held that notice u/s. 148 of the Income Tax Act issued after obtaining sanction under section 151 from the non-competent authority is invalid and not sustainable in law. Accordingly, notice is liable to be quashed and petition is allowed.
