The Delhi ITAT held that opening balances of unsecured loans cannot be treated as unexplained cash credits under Section 68 when no fresh funds were received during the relevant year. The Tribunal deleted additions after finding that the Assessing Officer wrongly included brought-forward balances.
The Tribunal held that mere disallowance of deduction claimed under Section 80GGC does not automatically amount to misreporting of income. It deleted the penalty as there was no evidence of false particulars or fabricated documents.
The Tribunal held that the enhanced exemption limit of ₹25 lakh under CBDT Notification No. 31/2023 applies to leave encashment claims under Section 10(10AA)(ii). Full exemption of ₹10.15 lakh was allowed to the retired SBI employee.
The Tribunal held that unsigned documents and Tally entries seized from a developer’s premises cannot justify additions without corroborative evidence. It ruled that no addition can survive merely on third-party material lacking proof of actual cash movement.
The Tribunal ruled in favour of the assessee after noting that audited financials, PAN, bank statements, ITRs, confirmations, and MCA records of lenders were furnished. The ruling reinforces that documentary evidence can successfully rebut allegations of bogus loans.
The Tribunal ruled that a clerical mistake in quoting TAN cannot result in denial of TDS credit when Form 16 and Form 26AS clearly establish tax deduction. The decision emphasizes substance over procedural technicalities.
The Tribunal ruled that mere observations about cash transactions are insufficient to levy penalty under Section 271D. A specific finding establishing contravention of Section 269SS is mandatory before imposing penalty.
The Hyderabad ITAT held that only the actual period lost during the limitation period can be excluded under Explanation-1 to Section 153. It ruled that the assessment order passed beyond the permissible period was invalid.
The Tribunal ruled that the word purchase under Section 54 must receive a liberal and purposive interpretation. Genuine investment in a residential property within the prescribed period can qualify for exemption even without a registered conveyance deed.
The Kolkata ITAT held that the Assessing Officer cannot make arbitrary 10% expense disallowances without identifying specific defects or inflated claims. The Tribunal upheld deletion of ₹2.23 crore addition after finding the disallowance was based purely on guesswork and suspicion.
