The ITAT observed that invoking the test of human probabilities cannot replace factual verification of books and bank records. Additions under Section 69A require evidence showing that the disclosed cash was unavailable.
The ITAT found that provisions for identified legal and professional expenses represented crystallized liabilities requiring TDS deduction. The key takeaway is that only genuine contingent liabilities may escape such obligations.
The Hyderabad Bench emphasized that penalty under Section 271(1)(c) cannot be imposed solely because an addition survives appellate scrutiny. The Revenue must establish deliberate concealment or furnishing of inaccurate particulars.
The Hyderabad ITAT observed that if a property is treated as stock-in-trade, the applicability of Section 43CA cannot be ignored. The ruling clarifies that deeming provisions under Section 50C and Section 43CA operate in different contexts.
The Tribunal quashed the reassessment after finding that the Assessing Officer failed to issue notice under Section 143(2). The decision confirms that compliance with this statutory requirement is indispensable in reassessment proceedings.
The Tribunal quashed the reassessment after finding that the assessee had already filed the return under Section 139 before issuance of the notice. The key takeaway is that jurisdiction under Section 147 cannot be assumed on erroneous facts.
The Tribunal ruled that the Revenue cannot assess the full transaction value in the hands of a confirming party absent proof of beneficial ownership. The decision underscores the importance of establishing actual receipt of consideration.
ITAT deleted the addition after finding that neither possession nor ownership had passed during the relevant assessment year. The decision emphasizes that actual transfer, not mere intention to sell, determines taxability.
ITAT held that proving the mode of payment is not enough to secure deduction for political contributions where evidence points to a bogus donation scheme. Taxpayers must establish the authenticity of the entire transaction.
ITAT Delhi held that reassessment cannot survive when additions are made on issues unrelated to the reasons recorded for reopening. The ruling reinforces that the scope of reassessment must remain confined to the original basis of jurisdiction.
