873 orders · Page 13 of 18
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal restored the appeals back to the PCIT to await the final outcome of proceedings for assessment year 2012-13, which are pending before the Supreme Court. The assessee is at liberty to raise all contentions in the subsequent proceedings.
The Tribunal held that an assessment framed in the name of a non-existent entity, after being informed of a merger, is a curable defect and is void ab initio. The assessment proceedings are to be treated as non-existent in the eyes of law.
The Tribunal noted that the assessee's prior appeals were dismissed with liberty to revive after moratorium. Given this context and the submission regarding the commencement of liquidation, the Tribunal found the Revenue's appeal deserved dismissal, with liberty to revive.
The Tribunal held that the source of the cash was explained as it was withdrawn by LLPs and kept with the assessee's father. The addition made by the AO was not sustainable and was deleted.
The Tribunal held that the notice issued under the unamended Section 148, served after the effective date of the amended provisions, was invalid. Consequently, the assessment framed based on this defective notice was void ab initio.
The Tribunal held that the CIT(A), being a quasi-judicial authority, was duty-bound to decide the jurisdictional issues raised by the assessee before adjudicating on merits. The Tribunal restored the appeal to the CIT(A) for deciding the jurisdictional grounds before considering the additions.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal allowed the appeal regarding the disallowance under Section 14A, stating the Assessee did not earn dividend income and there was no finding that expenditure was incurred to earn exempt income. The disallowance for delayed employee contribution was dismissed as not pressed. The disallowance of interest on unsecured loan was allowed, following the Tribunal's own order for a prior assessment year.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal held that the CIT(A) erred in deleting additions for certain investors as complete documentation regarding the genuineness of transactions and creditworthiness was not provided. The Tribunal found that the CIT(A) confirmed additions for other investors correctly due to incomplete or missing documentation.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal held that the one-time life membership fee received by the assessee should not be treated as a revenue receipt. The consistent practice of the assessee and the principles of real income theory support its treatment as a capital receipt with a portion recognized over time.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the appeals stem from a common search action and subsequent section 153C proceedings. The Assessing Officer's assessment order indicated that non-genuine bills were provided to the assessee by another party.
The Tribunal held that since the section 153C notice was issued in 2021, the assessment years were unabated. The Revenue's contentions supporting the impugned assessments lacked merit, and the assessments were quashed.
The Tribunal held that since the section 153C notice was issued in 2021, the assessment years were unabated. The Revenue's contentions supporting the impugned assessments lacked merit, and the assessments were quashed.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal held that the grounds related to the validity of the assessment order due to the issuance of the notice under Section 143(2) on the same day as the return filing were legal in nature and admitted for adjudication. However, the judgment does not explicitly detail the finding on these specific legal grounds concerning the procedural validity of the notice under Section 143(2) and the initiation of proceedings under Section 147. Regarding the addition of INR 8,89,37,168/- as LTCG, the Tribunal held that the ancestral lands were inherited by the assessee's family from their forefathers and were thus HUF property. The sale consideration was received by the assessee on behalf of the smaller HUF of his family. Therefore, the capital gains should be assessed in the hands of the HUF, not the assessee in his individual capacity. The Tribunal directed the AO to delete the additions made in the assessee's individual hands and take necessary action in the hands of the HUF. Regarding the addition of INR 75,000/- for agricultural income, the Tribunal found no infirmity in the lower authorities' order as the assessee failed to produce any evidence, and thus dismissed this ground. The appeal was partly allowed.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.
The Tribunal noted that the assessee wished to withdraw the appeals for AY 2010-11 and AY 2011-12, as they were self-explanatory and the CIT-DR had no objection. Consequently, these appeals were dismissed as withdrawn.