ITAT Chandigarh Judgments — November 2024

The Tribunal held that the Assessing Officer lacked jurisdiction under Section 153C as the seized material did not correlate with the assessment years in question. Consequently, the assessment orders were set aside.

The Tribunal held that the Assessing Officer lacked jurisdiction under Section 153C as the seized material did not correlate with the assessment years in question. Consequently, the assessment orders were set aside.

The Tribunal set aside the CIT(A)'s order and restored the matter to the Assessing Officer for a fresh assessment. The assessee was granted an opportunity to present their case.

The Tribunal held that the first proviso to section 12A(2) is a beneficial provision and should be applied retrospectively. Consequently, the assessee is entitled to the benefit of sections 11 and 12 for the assessment year under consideration.

The Tribunal held that the Assessing Officer lacked jurisdiction under Section 153C as the seized material did not correlate with the assessment years in question. Consequently, the assessment orders were set aside.

The Tribunal held that the Assessing Officer lacked jurisdiction under Section 153C as the seized material did not correlate with the assessment years in question. Consequently, the assessment orders were set aside.

The Tribunal held that the AO's disallowance was based on assumptions and conjectures, disregarding the notarized affidavits and personal testimonies. The Tribunal found that the AO did not provide sufficient opportunity for cross-examination or rebuttals.

The Tribunal held that the first proviso to Section 12A(2) is applicable, allowing the benefit of Sections 11 & 12 for preceding assessment years if the assessment is pending and registration is subsequently granted. The CIT(E) was directed to grant the benefit accordingly.

The tribunal considered the withdrawal application submitted by the assessee. The Revenue did not object to the withdrawal.

The Tribunal held that tax authorities should assist assessees with bona fide mistakes and that legal claims not made before lower authorities can be made before appellate authorities. The AO was directed to examine the Section 54F/54B claim.

The Tribunal held that the compensation received under the Voluntary Retirement Scheme (VRS) is eligible for exemption under Section 10(10B) of the Act. The Assessing Officer was directed to provide relief as per Section 89 for the net gratuity amount.

The tribunal set aside the ex-parte order of the CIT(A). The matter was restored to the CIT(A) for a decision on merits after providing the assessee an opportunity to present their case.

The Tribunal held that an unsigned return is not invalid, especially when acknowledged by the department and acted upon by the AO. The revisionary order by the PCIT was deemed erroneous as it was based on a trivial defect and lacked proper opportunity for the assessee.

The Tribunal held that only the profit element embedded in purchases from known sources can be added, not the entire purchase value. Considering the assessee's historical net profit rates and the offered rate, no additions were warranted.

The Tribunal held that the assessee had not discharged the onus to prove the identity, creditworthiness, and genuineness of the investors. The AO was justified in treating the unexplained share capital and premium as income.

The Tribunal held that the assessee had not discharged the onus to prove the identity, creditworthiness, and genuineness of the investors. The AO was justified in treating the unexplained share capital and premium as income.

The Tribunal held that the CIT(A)'s order was ex-parte and in violation of natural justice because notices were sent to an incorrect email address. Therefore, the order was set aside.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that the levy of interest under sections 234A, 234B, and 234C is mandatory and the AO was justified in invoking section 154. However, the levy is consequential to additions made, so if additions are deleted in quantum appeals, the interest will also be deleted.

The Tribunal held that additions under Section 153A are not sustainable if no incriminating material was found during the search, especially when the original assessments were already completed. The Tribunal relied on the Supreme Court's decision in PCIT vs. Abhisar Buildwell (P) Ltd.

The Tribunal set aside the ex-parte order of the CIT(A) and remanded the matter back for fresh adjudication. The assessee was granted an opportunity to present his case properly.

The Tribunal held that no additions can be made in the absence of incriminating material found during a search, especially when the assessment was already completed and non-abated. This decision was based on the Supreme Court's ruling in PCIT Vs Abhisar Buildwell (P) Ltd.

The Tribunal held that additions under Section 153A are not sustainable if no incriminating material was found during the search, especially when the original assessments were already completed. The Tribunal relied on the Supreme Court's decision in PCIT vs. Abhisar Buildwell (P) Ltd.