The High Court held that the Tribunal exceeded its limited powers under Section 254(2) by recalling a final order on merits. Once the recall was struck down, the original favourable order stood automatically restored.
The ITAT held that equity share purchases routed through the disclosed bank account cannot be treated as unexplained without proper verification. The AO was directed to provide transaction details and re-examine the source to avoid double additions.
The Tribunal held that interest earned by a co-operative credit society from fixed deposits with co-operative banks remains deductible under Section 80P(2)(a)(i). Such interest is attributable to the business of providing credit facilities to members, even after the Totgars ruling.
The Tribunal held that income admitted during search cannot be treated as undisclosed income unless supported by incriminating material found in the search. In the absence of such material, penalty under Section 271AAB cannot be sustained.
Only income supported by cash actually found during search could attract penal consequences. The balance amount, unsupported by incriminating material, was held outside the scope of Section 271AAB.
The Tribunal observed that rejection of audited books and disallowance of labour charges must be backed by concrete defects. Purely ad-hoc estimations based on minimum wages were held improper.
The Tribunal held that GST paid during the relevant year is allowable under Section 43B even if it relates to an earlier period. Since the amount was actually paid and not claimed earlier, disallowance was unjustified.
The Tribunal found that notices issued manually by the jurisdictional officer contravene the faceless reassessment framework. There is no concurrent jurisdiction between faceless and jurisdictional officers. Any reassessment initiated this way is invalid from inception.
ITAT Jaipur held that assessment under section 153C of the Income Tax Act stands quashed due to lack of jurisdiction since there was no transfer of the case of the assessee from Delhi to Jaipur.
The Tribunal held that after 29-03-2022, only a Faceless Assessing Officer is empowered to issue notices under Section 148. Notices issued by a jurisdictional officer were declared void, vitiating the entire reassessment.
