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.
ITAT Delhi held that addition under Section 41(1) cannot be made without proving cessation of liability. The Tribunal found that family loans continued to remain payable and were merely reclassified in the capital account.
ITAT Raipur held that additions based on server data, search records, and investigation reports cannot survive if such material is not supplied to the assessee. The Tribunal ruled that denial of rebuttal opportunity violates principles of natural justice.
The Tribunal upheld disallowance of deduction under Section 80GGC after finding the political donation lacked genuineness. The ruling highlights that payments through banking channels alone cannot establish a valid deduction when surrounding facts indicate accommodation entries.
The Tribunal held that cash deposits during demonetisation cannot be treated as unexplained when backed by audited books, invoices, stock records, and VAT returns. The ruling clarifies that genuine business sales cannot trigger Section 68 merely due to acceptance of old currency notes.
The Tribunal ruled that non-specification of the precise statutory charge under sections 270A(2) and 270A(9) violated principles of natural justice. Penalty proceedings were therefore held invalid and unsustainable.
The Tribunal ruled that addition of alleged undisclosed income could not be sustained merely on the basis of WhatsApp chats without supporting enquiry or evidence. It held that the department failed to establish any actual transaction involving the assessee.
The Tribunal quashed the assessment after finding that crucial JSK Server data, screenshots, and investigation records were never provided to the assessee. The ruling reiterates that additions based on undisclosed evidence violate principles of natural justice.
ITAT Bangalore held that profit cannot be estimated arbitrarily when regular books of account are maintained and not rejected under the Income Tax Act. The Tribunal ruled that mere decline in net profit rate does not justify ad hoc additions without evidence of suppressed sales or inflated expenditure.
The Jodhpur ITAT held that penalty under Section 272A(1)(d) could not survive where the Assessing Officer completed scrutiny assessment under Section 143(3) after considering replies and documents furnished later by the assessee.
