The Bombay High Court held that bad debt deduction cannot be denied where the debt was effectively written off through accounting entries despite the debtor’s account remaining open due to pending litigation. The ruling emphasizes substance over accounting form.
The ITAT held that the Assessing Officer must clearly indicate whether the alleged default is under-reporting or misreporting, as both attract different consequences under Section 270A. Failure to do so rendered the penalty order invalid.
ITAT Ahmedabad held that the tax authorities failed to consider evidence of an earlier agreement and prior payments before invoking Section 56(2)(x). The addition based on the stamp duty value was deleted.
ITAT Jaipur held that proceedings under Section 153C are invalid where the Assessing Officer merely reproduces information from the searched person’s AO without independently examining seized material. The Tribunal ruled that independent satisfaction is a mandatory jurisdictional requirement.
The ITAT Hyderabad held that an uncorroborated loose sheet could not justify an addition under Section 69 for alleged on-money payment. The Tribunal upheld deletion of the addition as no independent evidence supported the Revenue’s case.
The Calcutta High Court held that a sanction order must reflect consideration of the taxpayer’s explanation and provide reasons for rejecting it. As these requirements were absent, the sanction order was quashed and remanded for reconsideration.
ITAT Hyderabad held that the assessee was denied a fair hearing because appellate notices were not served in the mode opted in Form 35. The case was remanded to the CIT(A) for fresh adjudication after providing a proper opportunity.
The ITAT ruled that deduction of TDS does not excuse failure to file an income tax return. The decision emphasizes that income discovered through departmental records can attract penalty for under-reporting under Section 270A.
The ITAT Bangalore held that no disallowance under section 14A read with Rule 8D can be made where the assessee did not earn exempt income during the year. The ruling reiterates that, for years prior to AY 2022-23, absence of exempt income bars such disallowance.
The Court emphasized that reassessment proceedings must comply with principles of natural justice by providing an effective opportunity of hearing. Ignoring explanations and documents submitted by the taxpayer vitiates the entire reopening process.
