The Tribunal ruled that cash deposits arising from regulated liquor sales are a normal business incident. Where bank reconciliations explain the source, Section 69A cannot be invoked.
The addition on shares contributed to a family trust was deleted as the trust was exclusively for the benefit of relatives. Section 56(2)(x) does not apply where the statutory exemption conditions are satisfied.
The disallowance of interest income was set aside as co-operative banks fall within the definition of co-operative societies. The ruling confirms full deductibility of such interest under Section 80P(2)(d).
The Tribunal held that interest earned by a co-operative society from investments with co-operative banks falls within Section 80P(2)(d). Such income is deductible, subject to verification of the source and bifurcation.
Cash deposits followed by regular transfers to the telecom operator established a clear business cycle. The ruling confirms that explained business receipts cannot be treated as unexplained cash.
The Tribunal held that a Section 148A(d) order passed by a jurisdictional AO after the faceless notification is without legal authority. Any reassessment founded on such an order is void for want of jurisdiction.
The Tribunal ruled that post-notification reassessment notices must strictly follow the faceless assessment framework. Issuance by a jurisdictional AO renders the notice without authority and the reassessment unsustainable.
The Tribunal held that where reassessment is based solely on search material found during a third-party search, proceedings must be initiated under section 153C. Reopening under section 147 was held to be without jurisdiction and quashed.
The Tribunal held that corpus donations cannot be denied merely due to technical lapses like student collection or minor PAN errors. Donor intent and consistent treatment in books were sufficient to allow exemption under section 11(1)(d).
ITAT ruled that unverified electronic records recovered from a third party do not constitute reliable evidence of cash payments. Additions based solely on such data were deleted.
