Applying the test of human probabilities, the Tribunal ruled that unexplained abnormal sales could not be fully accepted. At the same time, absence of book defects warranted estimation instead of outright section 68 taxation.
The Tribunal held that a one-day delay in depositing employees’ PF caused by proven payment gateway failure constitutes impossibility of performance. Genuine attempts and evidence justified allowing the deduction despite strict timelines.
The Tribunal ruled that CIT(A) exceeded jurisdiction by remanding a completed scrutiny assessment. The decision clarifies that remand powers apply only to Section 144 assessments, not regular ones.
The issue was whether further disallowance could be made after a suo motu 30% disallowance under section 40(a)(ia). The Tribunal ruled that any additional adjustment amounts to double disallowance and is impermissible.
The issue was whether a regular assessment could survive once section 153C was triggered for a non-searched person. The Tribunal ruled that pending scrutiny abates, making an assessment under section 143(3) void from inception.
The issue was whether reassessment can stand on an unsigned notice under Section 148. ITAT held that an unsigned notice confers no jurisdiction, rendering the reassessment void ab initio.
The ITAT held that an unsigned and unexecuted seized agreement cannot establish receipt of cash. The key takeaway is that additions under Section 69A require proof of actual receipt, not mere allegations.
The Tribunal set aside an addition made only on documents seized from a builder during search proceedings. The ruling underscores that independent evidence against the assessee is mandatory.
The question was whether execution proceedings could extend to directors despite no findings against them. The Court ruled that directors cannot be bound in execution without pleadings, adjudication, and findings in the original proceedings.
The issue was whether reassessment notices issued by the Jurisdictional AO were valid after the faceless regime. ITAT held that post-notification, only the Faceless AO could act, rendering the reassessment void.
