Tax Relief Granted: Partial Win for Assessee with Remand on Multiple Taxation Challenges Under Sections 251(2) and 14A

ITAT adjudicated multiple taxation issues, allowing partial relief to the assessee. The tribunal primarily focused on procedural and jurisdictional challenges, remanding certain matters back to the Assessing Officer (AO) for fresh verification. Key holdings included: (1) CIT(A) lacked jurisdiction to enhance income through new sources under section 251(2), (2) advances written off to be re-examined by AO with fresh evidence, (3) no disallowance under section 14A due to absence of exempt income, and (4) PF and ESI contribution delays to be reassessed based on salary disbursement dates. The tribunal's approach emphasized procedural fairness and detailed factual re-examination rather than conclusive substantive determinations. .....

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