ITAT Chandigarh Judgments — June 2025

The Tribunal noted that the assessee failed to make an effective representation before the lower authorities. Considering principles of natural justice and potential communication gaps, the Tribunal set aside the order and restored the case to the AO for de novo assessment, allowing the assessee an opportunity to substantiate its case.

The Tribunal noted that the assessee had received the consequential relief and no longer wished to pursue the appeal. The appeal was dismissed as withdrawn.

The Tribunal held that assessments under Section 153C are invalid without a proper satisfaction note from the Assessing Officer of the searched person and the assessee. For AY 2019-20, the addition was deleted as it was based on DVO valuation without rejecting the assessee's books and without concrete incriminating material.

The Tribunal held that the reasons provided for the inordinate delay were not convincing and that the appeal was filed after a consequential order had already been passed, making it liable for dismissal at the threshold on the ground of delay.

The Tribunal held that assessments under Section 153C are invalid without a proper satisfaction note from the Assessing Officer of the searched person and the assessee. For AY 2019-20, the addition was deleted as it was based on DVO valuation without rejecting the assessee's books and without concrete incriminating material.

The Tribunal held that assessments under Section 153C are invalid without a proper satisfaction note from the Assessing Officer of the searched person and the assessee. For AY 2019-20, the addition was deleted as it was based on DVO valuation without rejecting the assessee's books and without concrete incriminating material.

The Tribunal held that assessments under Section 153C are invalid without a proper satisfaction note from the Assessing Officer of the searched person and the assessee. For AY 2019-20, the addition was deleted as it was based on DVO valuation without rejecting the assessee's books and without concrete incriminating material.

The Tribunal held that assessments under Section 153C are invalid without a proper satisfaction note from the Assessing Officer of the searched person and the assessee. For AY 2019-20, the addition was deleted as it was based on DVO valuation without rejecting the assessee's books and without concrete incriminating material.

The Tribunal held that since the hearing notices were not received by the assessee, it was not a fit case for imposing a penalty. The penalty was accordingly deleted.

The Tribunal held that to uphold the principles of natural justice and considering potential communication gaps in the faceless regime, the assessee should be given another opportunity to present their case before the CIT(A).

The Tribunal, considering the principles of natural justice and potential communication gaps in the faceless regime, decided to grant the assessee another opportunity to be heard. The impugned order was set aside, and the matter was restored to the CIT(E) for fresh consideration.

The Tribunal found that while the assessee's activities were in the initial stages and not fully commenced, they were not found to be non-charitable. The rejection was based on apprehension rather than concrete findings of violations. Therefore, the Tribunal set aside the CIT's orders.

The Tribunal, by following the ratio decided by the Hon'ble Supreme Court in the case of 'Checkmate Services Pvt. Ltd. Vs. CIT', found no reason to interfere with the findings of the CIT(A). The appeal of the assessee was dismissed.

The Tribunal held that interest on employee and employer contributions, as well as employer's contribution, were correctly treated as taxable income. However, for employee's contribution, since no deduction under section 80C was claimed in earlier years, the adjustment made by CPC to tax this amount was unjustified and deserved to be deleted.

The Tribunal held that the assessee failed to prove the genuineness and creditworthiness of the lender, Smt. Surjeet Kaur, and therefore, could not establish the source of the unsecured loans. The reassessment jurisdiction was also upheld as the reopening was based on tangible material indicating escapement of income.

The Tribunal held that the assessee is performing statutory functions as a regulatory body for the pharmacy profession, which is a public function. Relying on the Apex Court's decision in CIT vs. Ahmedabad Urban Development Authority, the Tribunal ruled that monies charged for public services by statutory authorities are not to be considered commercial receipts. The Tribunal also noted that similar organizations had been granted registration.

The Tribunal held that the non-maintenance of a stock register, especially for a business dealing with numerous small items, is not a sufficient ground to reject the books of accounts when no other defects are found. Similarly, an incorrect method of stock valuation does not automatically invalidate the books. The AO was directed to re-determine the stock value using the correct method.