10 orders · Page 1 of 1
The High Court dismissed the Revenue's appeal, affirming the ITAT's decision. It held that the AO had conducted a detailed inquiry, and a mere change of opinion cannot justify invoking Section 263, as the AO's order was not prejudicial to the Revenue.
The High Court dismissed the appeals, upholding the ITAT's decision. It affirmed that an assessment based on third-party statements without allowing cross-examination violates natural justice and renders the order a nullity. The court found no substantial question of law arose, noting that the ITAT had satisfactorily dealt with the factual aspects of the assessee's transactions.
The High Court dismissed the appeals, affirming the ITAT's decision. It held that the primary issue was the violation of natural justice due to the denial of cross-examination of third-party statements used by the AO. The Court found that the appellant's arguments pertained to factual aspects already dealt with by the ITAT, and thus, no substantial question of law arose.
The High Court, relying on its earlier decision in a connected case and the Supreme Court's judgment in *Ahmedabad Urban Development Authority*, held that JDA's activities are charitable in nature. Consequently, it upheld the Income Tax Appellate Tribunal's decision to grant exemption under Section 11 of the Act, dismissing the department's appeals.