The ITAT held that reassessment cannot be sustained when additions are ultimately made on issues not mentioned in the recorded reasons for reopening. The AO’s jurisdiction failed because no valid addition survived on the original escapement issue.
Tribunal held that purchase of land outside the prescribed period does not automatically disqualify exemption on construction of a residential house. Construction expenditure incurred within the time limit prescribed under Section 54 may still qualify for deduction. The issue was remanded for verification of actual construction costs.
The Tribunal emphasized that once sales are entered in regular books and supported by stock records, the burden shifts to the Revenue to prove them false. In the absence of such proof, Section 68 could not be invoked.
ITAT Delhi held that cash deposits made during the demonetization period could not be fully treated as unexplained money when supported by sales records and books of account. However, as the assessee failed to satisfactorily explain the abnormal increase in cash sales before demonetization, the Tribunal sustained only a lump-sum addition of ₹10 lakh. The ruling emphasizes balanced evaluation of evidence in demonetization-related assessments.
ITAT Delhi held that reassessment under Sections 147/148 cannot be based on the same material already examined during a completed Section 153C assessment. The ruling emphasizes that fresh tangible material is necessary for valid reopening.
The guide explains the enhanced rebate mechanism available under the new tax regime and the revised slab structure applicable from AY 2026-27. It also discusses marginal relief and tax computation methodology.
The Tribunal held that the satisfaction note failed to identify the documents allegedly found during the search or their connection to the taxpayer. The ruling confirms that vague references to seized material are insufficient.
The Tribunal ruled that the Delhi Assessing Officer could not legally assess the taxpayer when jurisdiction continued to remain with Mumbai authorities. The decision underscores that jurisdiction cannot shift without following statutory procedures.
The Tribunal held that the Revenue failed to establish escaped income of ₹50 lakh or more, a prerequisite for extending the assessment period beyond six years. The ruling reinforces strict compliance with statutory thresholds for extended reassessment.
ITAT Delhi held that protective additions cannot survive when the same income has already been assessed substantively in the hands of the real beneficiaries. The key takeaway is that the Revenue cannot tax identical income twice in different hands.
