The issue involved purchases routed through entry providers to regularise grey-market transactions. The Tribunal held that taxing the whole purchase amount is incorrect; only excess profit may be assessed.
The Tribunal found that the assessee was penalized without substantive evidence or effective cross-examination. Holding this contrary to principles of natural justice, the penalty was deleted. The case highlights procedural fairness in penalty matters.
The Tribunal held that a clerical error in the tax audit report, later corrected through a revised report, cannot be the basis for disallowance under section 143(1). Automated adjustments must reflect correct facts.
The Tribunal ruled that an assessment based on a notice issued beyond the AO s pecuniary authority is unsustainable. Compliance with CBDT jurisdiction instructions was held mandatory.
The issue involved taxing a marginal valuation difference on property purchase. The Tribunal deleted the addition as the variation was below the statutory tolerance threshold. The decision confirms that minor deviations alone cannot be treated as taxable income.
ITAT held that Section 153C proceedings were invalid as the relevant years fell beyond the six-year window. Time limitation goes to jurisdiction and cannot be cured later.
The Tribunal held that unsecured loans cannot be treated as unexplained once lenders confirm transactions and respond to section 133(6) notices. Suspicion without evidence cannot justify section 68 additions.
The case examined whether disallowance under section 14A could be made when no expenditure relating to exempt income was claimed. The Tribunal held that unclaimed expenses cannot be disallowed. The ruling reinforces that section 14A applies only to deductions actually claimed.
The Tribunal held that assets received under a compliant scheme of demerger cannot be taxed under Section 56(2)(x). Transactions covered by Section 47 exemptions fall outside the scope of deemed income.
The Tribunal upheld deletion of additions where cash sales during demonetisation were backed by invoices, VAT payments, and statutory records. Statistical suspicion alone cannot override credible primary evidence.
