| Sec 11 & 12 |
Prof. J.P. Trivedi Memorial Trust |
Procedural Lapses: Exemption cannot be denied for delayed electronic filing of Form 10/10B or failing to specify accumulation purposes, as these are not “fatal” errors. |
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| Sec 92C |
Xchanging Solutions Ltd. |
TP Adjustment: If the DRP fails to pass a timely order to exclude comparables as directed by the ITAT, the AO must automatically remove them to correct the irregularity. |
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| Sec 143 |
Reliance Industries Ltd. (RIL) |
SC Ruling: Assessment orders passed in the name of amalgamated (non-existing) entities are void ab initio, even if the AO claims ignorance of the merger. |
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| Sec 148 |
UK Grid Solutions Ltd. |
SC Ruling: Reassessment cannot be sustained if the “reasons recorded” rely on surveys from different years without specific facts relating to the relevant AY. |
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| Sec 149 |
E-Homes Infrastructure |
Search Reopening: If no material belonging to the assessee is found in a third-party search, Sec 153C doesn’t apply, and reopening after 6 years is time-barred. |
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| Sec 254 |
Xchanging Solutions Ltd. |
ITAT Powers: While ITAT has wide powers, it can only give directions to the parties before it; it cannot issue orders to the TPO or DRP who are not direct parties. |
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