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.
The court held that tax liability cannot be increased at the appellate stage on a new ground without giving the assessee an opportunity of hearing. Enhancement without following Section 107(11) was set aside and remanded.
The Tribunal ruled that the Assessing Officer could issue a reassessment notice only within the balance days available after excluding the stayed period. Issuance beyond that surviving window renders the notice time-barred.
ITAT Delhi ruled that granting a common approval for several assessment years violates statutory safeguards. Search assessments collapse if approval is mechanical or omnibus in nature.
The Tribunal ruled that registration cannot be cancelled for non-maintenance of separate books when that allegation was never put to the assessee. Authorities must specify the exact clause of specified violation relied upon.
The High Court held that a reassessment notice issued without a manual or digital signature violates Section 282A of the Income-tax Act. Such an unsigned notice is invalid in law, rendering all consequential proceedings unsustainable.
The Tribunal found that the AO had examined land records, crop sale documents, and other evidence before making the assessment. Since due inquiry was conducted, the assessment order was neither erroneous nor prejudicial to revenue.
The assessment based on a second notice issued in July 2022 was quashed as time-barred. Once limitation had expired, subsequent notices could not revive reassessment jurisdiction.
The ITAT ruled that customer discounts are deductible when quantified and finalised in the year of claim, even if labelled as prior-period items. The decision reinforces that timing of crystallisation outweighs book classification.
