The issue was whether a recorded share investment can be treated as unexplained under Section 69. The Tribunal held that once an investment is recorded in the books and its source is not doubted, Section 69 cannot be invoked.
The issue was whether income disclosed during survey and duly reported in the return can attract penalty under Section 270A. The Tribunal held that when returned income equals assessed income, penalty provisions do not apply.
The Tribunal ruled that reopening beyond six years is invalid without a recorded satisfaction of undisclosed assets exceeding ₹50 lakh. The takeaway is strict compliance with the fourth proviso to section 153A is mandatory.
The reassessment relied entirely on allegations arising from a search on another entity. The Tribunal ruled that additions cannot survive without independent evidence directly linking the assessee.
The issue was whether reassessment is valid when reasons for reopening are not placed on record. The Tribunal held that non-recording of reasons under Section 148(2) vitiates jurisdiction, rendering the reassessment void.
The issue was whether third-party diaries and loose papers could establish receipt of unaccounted income. The Tribunal ruled that such papers, without authorship verification or corroboration, cannot fasten tax liability.
This ruling clarifies that an assessee can be treated as an agent of a non-resident only if income is received directly or indirectly for the NRI. In the absence of such receipt or business connection, representative assessment fails.
The issue was whether the NCLT could declare ownership of a trademark during CIRP. The Supreme Court held that title disputes not arising directly from insolvency fall outside Section 60(5) jurisdiction.
The Tribunal held that while fee suppression was established during survey proceedings, the entire difference could not be taxed. Only the gross profit on suppressed receipts, excluding GST, is chargeable to tax.
The decision reiterates that when books of account, sales, and inventory are accepted, purchase disallowances cannot be made mechanically. Suspicion cannot replace proof in tax proceedings.
