The ITAT held that revision under Section 263 cannot be invoked where the Assessing Officer has conducted detailed inquiries and adopted a plausible view. The Tribunal ruled that a mere change of opinion by the PCIT does not render the assessment order erroneous or prejudicial.
The Tribunal held that entire purchases cannot be disallowed when corresponding sales are accepted. It upheld restriction of addition to profit element, preventing unrealistic income computation.
The Court clarified that recovery actions must be confined to the assessee liable for tax. Attaching a director’s personal account without evidence of liability was held unlawful. The judgment underscores limits on recovery powers.
The issue involved expiring tenures of tribunal members and lack of replacement mechanisms. The Supreme Court permitted a uniform extension framework up to September 2026. The decision aims to maintain operational tribunals pending legislative reform.
The Tribunal upheld the disallowance of HRA exemption under Section 10(13A) as the assessee failed to submit any supporting documents for rent payments. In the absence of evidence, the claim of ₹1,08,000 was rightly disallowed.
The Madras High Court held that penalty under Section 271(1)(c) cannot be imposed where a DTAA claim was made based on a bona fide interpretation of law and full disclosure of income.
The High Court noted that large penalties were imposed on corporate entities while the individual accused faced only a limited penalty, making the restriction on travel unjustified.
The Tribunal held that the sale of shares after holding them for nearly ten years could not be treated as a bogus penny stock transaction due to lack of evidence of manipulation.
A conclusion of an auction sale would not bar re-valuation of the auctioned property, when a question arises regarding the adequacy of valuation or fixation of the reserve price.
The Court expressed concern over unclear railway fund allocation and emphasized that spending must prioritize public safety and welfare. Railways were directed to submit a detailed affidavit explaining funding priorities.
