Emphasising settled law, the Tribunal ruled that properly documented loan transactions cannot be rejected without cogent contrary material. The CIT(A)s deletion of additions was therefore affirmed.
The issue was whether final assessment orders passed after DRP directions were barred by limitation under section 144C read with section 153. The Tribunal held that such orders passed beyond the statutory time limit are without jurisdiction and must be quashed.
The Tribunal examined suspicion surrounding a large cash advance for property. It ruled that suspicion alone cannot replace evidence, and once the transaction is substantiated, section 68 addition must be deleted.
The Tribunal held that a final assessment passed without giving effect to binding DRP directions violates section 144C. Such an order is void ab initio and cannot be sustained once the statutory time limit has expired.
It was ruled that the date of recording the satisfaction note is the deemed search date for a non-searched person. The ten-year limitation must be counted from this date, not from the original search.
The Tribunal deleted both substantive and protective additions made across multiple years on the same alleged receipts. It held that such duplication results in impermissible multiple taxation of identical amounts.
The appeal was dismissed solely on procedural grounds without hearing the assessee. The Tribunal held that the CIT(A) is duty-bound to decide appeals on merits after granting a proper opportunity.
The Tribunal examined whether Section 153A could be applied to the search year itself. It held that invoking Section 153A for the wrong assessment year was invalid, rendering the assessment void.
The Tribunal held that rural agricultural land excluded from capital asset under Section 2(14) cannot be taxed under Section 56(2)(vii)(b). Addition based on stamp duty valuation was therefore deleted in full.
The Tribunal held that serving notices on an outdated email ID violates principles of natural justice. The assessment was set aside and the matter restored for fresh adjudication after proper service.
