ITAT Agra held that additional evidence proving the land’s distance from municipal limits is crucial for reassessment under Section 56(2)(vii). The case was remanded to AO for de novo verification, allowing the assessee to file further supporting documents.
The Tribunal found that the AO failed to establish any bogus purchase or sale since the assessee never handled the goods and only received net surplus. Identical findings in earlier years compelled the ITAT to delete the same addition again. The takeaway is that established business patterns cannot be arbitrarily recharacterized as accommodation entries.
The Tribunal admitted additional evidence such as partnership deeds, royalty ledgers, and source-wise cash deposit mapping. Since AO never verified these materials, the addition under Section 69A could not be sustained. The issue was restored for proper factual examination.
Delhi High Court ruled that prosecution under Income Tax Act Sections 276C and 278E can proceed when evaded tax exceeds Rs.25 crores, even if appeals are pending, confirming proper authority delegation.
The Tribunal ruled that when no new loans are borrowed or granted, taxpayers need not re-prove nexus annually. Interest paid deduction under section 57(iii) was restored.
The ITAT ruled that property sold by a discontinued partnership must be taxed in the firm’s hands, not its former partners, emphasizing correct ownership for capital gains assessment.
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