The case examined whether entire purchases could be treated as bogus when sales were undisputed. The Tribunal restricted the addition to 6%, holding that only a reasonable estimation was warranted.
Recognizing the nature of the manufacturing business and accepted sales, the Tribunal scaled down the disallowance. The decision stresses pragmatic assessment. It avoids penalizing genuine turnover.
Interpreting Sections 21 and 22 together, the Court held that heirs inheriting an estate must maintain statutory dependants. A widowed daughter-in-law qualifies even if she did not receive a share in the estate. The decision clarifies obligations of successors.
The Tribunal clarified that expenditure disallowances do not qualify as assets under section 149(1). Without asset-based escaped income, reopening beyond three years is barred. This offers strong protection against belated reassessments.
The Tribunal examined whether website development charges were genuine business expenses. It upheld the disallowance after finding the vendor to be a non-existent entity and services to be unproven.
Chennai ITAT held that an appellate order passed in the name of a deceased assessee is void in law. The matter must be re-adjudicated after substituting the legal heir.
The Tribunal ruled that setting aside a best-judgment assessment after admitting additional evidence and remand findings is unjustified. CIT(A) must decide the case conclusively instead of granting a fresh lease to the AO.
The Tribunal held that a reassessment notice issued years after the assessee’s death is a legal nullity. Such proceedings are void even if the department was not informed about the death.
Applying settled law, the Tribunal held that penalties imposed after expiry of the limitation period are void. Both loan and repayment penalties were deleted across multiple years.
Mumbai ITAT held that additions cannot be sustained merely due to Form 26AS mismatches. The Assessing Officer must verify whether income was already taxed to avoid double taxation.
