The ruling clarifies that unverified excel sheets seized from third parties cannot justify additions without corroborative evidence. The Tribunal stressed that assumptions cannot replace proof in tax proceedings.
The Tribunal held that failure to issue a jurisdictional transfer order under Section 127 invalidates the assessment. It ruled that absence of such order renders proceedings void ab initio, irrespective of merits.
ITAT held that additions based solely on third-party search material without independent evidence or cross-examination are invalid. The burden of proof lies on the department.
The case examined whether purchases can be disallowed when supported by documents and sales are accepted. ITAT held that estimation without rejecting books or independent evidence is unsustainable.
The issue was whether purchases could be treated as bogus based on investigation reports. ITAT held that when documentary evidence and asset existence are proven, additions cannot be sustained.
The issue was whether machinery replacement qualifies as current repairs. The Court held that replacement creating enduring benefit constitutes capital expenditure.
The Court held that rejecting condonation solely because the assessment year was not mentioned in the circular is unjustified. It ruled that beneficial circulars must be applied liberally to address genuine hardship.
The Tribunal held that purchases cannot be treated as bogus when supported by invoices, bank payments, and GST records. It ruled that absence of adverse evidence makes such additions unsustainable.
ITAT held that once an assessee adopts a prescribed valuation method under Rule 11UA, the AO cannot change or substitute it. The ruling reinforces taxpayer autonomy in selecting valuation approaches.
The Tribunal held that reopening an assessment on identical material already examined is invalid. It ruled that reassessment cannot be used to revisit concluded issues without fresh evidence.
