The Tribunal held that penalty under section 271(1)(c) cannot be imposed when errors are voluntarily corrected during assessment. Bona fide computational mistakes without concealment do not amount to furnishing inaccurate particulars.
The Tribunal upheld deletion of addition as seized loose sheets lacked key details and no supporting evidence proved unaccounted sales. Reliance solely on such documents was held insufficient.
The tribunal held reopening invalid where actual escaped income was below ₹50 lakh. It clarified that jurisdiction depends on real income, not transaction value.
The Tribunal held that delay in filing Form 10-IC does not invalidate the option exercised under Section 115BAA if declared in the return. It ruled that the requirement is procedural, not mandatory. The decision ensures substantive tax benefits are not denied due to technical lapses
ITAT held that addition under Section 69B based only on a loose sheet seized from a third party cannot be sustained when the assessee was denied cross-examination. The ruling treats such action as a violation of natural justice.
The ITAT held that the Assessing Officer erred in adding corpus donations to annual receipts to deny exemption under Section 10(23C)(iiiad). Recognizing such donations as capital receipts, the Tribunal restored the tax exemption.
The Court ruled that when an assessee certifies stock statements given to a bank as accurate and consistent with books, discrepancies can justify tax additions. The explanation that the figures were inflated merely to obtain higher credit was rejected.
The ITAT Gauhati ruled that relief under Section 89(1) cannot be denied solely because Form 10E was not filed before the due date. The Tribunal held that procedural lapses should not defeat substantive tax relief where eligibility is otherwise established.
ITAT ruled that jurisdiction to reopen assessment arises only when a valid notice is issued to a living person or legal representative. Since the notice was issued to a deceased assessee, the reassessment order was declared illegal.
ITAT ruled that denial of TDS credit due to a PAN mismatch between the deceased and the legal heir is unjustified. Once the income is taxed in the hands of the legal heir, the corresponding TDS credit must also be granted.
