The Tribunal ruled that an assessment based on a notice issued beyond the AO s pecuniary authority is unsustainable. Compliance with CBDT jurisdiction instructions was held mandatory.
The issue involved taxing a marginal valuation difference on property purchase. The Tribunal deleted the addition as the variation was below the statutory tolerance threshold. The decision confirms that minor deviations alone cannot be treated as taxable income.
ITAT held that Section 153C proceedings were invalid as the relevant years fell beyond the six-year window. Time limitation goes to jurisdiction and cannot be cured later.
The Tribunal held that unsecured loans cannot be treated as unexplained once lenders confirm transactions and respond to section 133(6) notices. Suspicion without evidence cannot justify section 68 additions.
The case examined whether disallowance under section 14A could be made when no expenditure relating to exempt income was claimed. The Tribunal held that unclaimed expenses cannot be disallowed. The ruling reinforces that section 14A applies only to deductions actually claimed.
The Tribunal held that assets received under a compliant scheme of demerger cannot be taxed under Section 56(2)(x). Transactions covered by Section 47 exemptions fall outside the scope of deemed income.
The Tribunal upheld deletion of additions where cash sales during demonetisation were backed by invoices, VAT payments, and statutory records. Statistical suspicion alone cannot override credible primary evidence.
The Tribunal held that a penalty notice which does not specify the exact charge is invalid. Failure to strike off the irrelevant limb shows non-application of mind and vitiates penalty proceedings.
The dispute involved taxability of large cash deposits made during demonetisation. The appellate authority granted relief for deposits in regular notes while sustaining the balance as unexplained income. The Tribunal upheld this approach, finding it consistent with law and facts.
The Tribunal held that assessments beyond the permissible six-year block under section 153C are invalid. Proceedings were quashed as the relevant years fell outside the statutory limitation.
