The issue was whether statements and digital records from Customs probes could support FEMA action. The Tribunal ruled they are admissible and sufficient to establish illegal foreign exchange payments.
The case examined whether penalty quantum should reflect the appellant’s role in the transaction. The Tribunal reduced the penalty after noting the dominant involvement of a third party and lack of comprehensive investigation.
No on-money addition was made in the cases of other co-owners of the same property. The ITAT held that the Revenue cannot adopt a contradictory stand on identical facts.
The issue was whether a buyer could be taxed for alleged cash payment based only on the seller’s admission. The Tribunal ruled that in the absence of direct or corroborative evidence, no on-money addition can be sustained in the buyer’s hands.
The Tribunal ruled that the reassessment was time-barred because limitation was wrongly computed from the search date. The key takeaway is that receipt of seized material governs jurisdiction for non-searched persons.
Capital gains arose from land compulsorily acquired by a government authority. ITAT directed the AO to re-examine eligibility for exemption under Section 10(37).
The Revenue disallowed 80P deduction by treating FDR interest as income from surplus funds. ITAT ruled Totgars applies only to surplus funds, not to statutory reserves mandated by co-operative law.
ITAT Ahmedabad held that if a Section 263 revision order is quashed, any consequential assessment and appeals based on it are rendered inoperative. Key takeaway: assessments cannot stand on invalid foundations.
The reassessment was initiated for AY 2013-14 using reasons recorded for AY 2012-13. ITAT held that reopening for the wrong year is void, causing the entire Section 147 assessment to collapse.
ITAT Jaipur confirmed that Section 270A(6)(b) exclusion is inapplicable when accounts are incorrect or incomplete. Key takeaway: defective records make estimated disallowances liable to penalty.
