The Supreme Court held that reassessment notices issued after the six-year limit are barred. It affirmed that expired cases cannot be revived under later provisions.
The issue concerned overlap of deductions under Sections 80-IA and 80HHC. The Court held that 80HHC profits cannot be reduced by 80-IA deduction, ensuring independent computation.
The tribunal held that cash deposits backed by sales records cannot be treated as unexplained income. It upheld deletion of addition where transactions were properly documented.
The assessee produced new evidence including invoices and tax returns of suppliers. The Tribunal held that these documents must be examined before deciding the issue.
The issue involved taxation of capital gains based on a disputed land sale. The Tribunal held that once the sale deed was declared void, no capital gains could arise.
The issue involved enhancement of value of imported second-hand machinery. The Tribunal held that rejection of the load port certificate was unjustified, restoring the declared transaction value.
The tribunal held that TDS credit cannot be claimed by an agent when the underlying income belongs to farmers. It ruled that credit must align with the person offering the income to tax.
The Court held that once GSTAT is operational and timelines are extended, disputes must be pursued through the appellate mechanism. Writ petitions cannot continue when an effective statutory remedy exists.
The Court held that penalty under Section 73 cannot be imposed without justification even where tax liability is admitted. It allowed reconsideration of the issue while confirming liability to pay interest on delayed payment. The ruling emphasizes that penalty is not automatic.
Dispute on ITC mismatch between returns was remitted after ex-parte order, allowing reconciliation upon 10% pre-deposit. Key takeaway: reconciliation issues must be examined with proper hearing.
