The Tribunal ruled that unexplained investment additions based solely on a DVO report are invalid when books are not rejected and the report is not confronted to the assessee. The matter was remanded for fresh verification following natural justice.
The issue was whether income of a predecessor company for years before amalgamation can be reassessed in the hands of the successor. ITAT held that such clubbing is impermissible and the reassessment itself is void.
The Tribunal held that a bona fide mistake in claiming deduction under an incorrect section should not bar relief. The matter was remanded to verify eligibility under section 35(1)(ii).
The ruling clarifies that additions for unexplained investments cannot survive where credible evidence on source is later produced. The Tribunal restored the issue to the Assessing Officer to examine bank records and property sale proceeds.
While sales proceeds were claimed as the source, unexplained cash receipts appeared in the cash book. The Tribunal directed the Assessing Officer to re-examine deposits after detailed verification of records.
Where capital subsidy was not received in the relevant year and no addition followed, reopening lacked basis. Mechanical reliance on audit objections was held unlawful.
The issue was whether a seized loose paper alone can justify an on-money addition under section 69. ITAT held that without independent corroboration, such addition cannot be sustained.
The Tribunal examined whether a single, consolidated satisfaction note for multiple assessment years meets the requirement of Section 153C. It held that such consolidated recording vitiates jurisdiction, rendering the search assessments void.
The Tribunal upheld additions in search assessments where seized material and settled precedent supported the Revenue’s case. The ruling clarifies that group-level incriminating evidence can justify section 153A additions.
The issue was whether a penalty can survive when the show cause notice fails to specify the exact charge. ITAT held that a vague notice violates law, making the entire penalty unsustainable.
