The PCIT sought to revisit claims already scrutinized and partly disallowed. The Tribunal ruled this to be a change of opinion and invalid. Revision demands clear error and prejudice, not reappraisal.
Accepting the assessee’s explanation for delay and non-appearance, the Tribunal condoned the delay and set aside both lower orders. The AO was directed to re-decide the issue of cash deposits after proper hearing.
Demonetisation cash deposits cannot be taxed merely on suspicion when supported by statutory VAT/Excise records, sales growth, and business expansion. Rule 46A(4) empowers CIT(A) to call for such evidence without triggering procedural violations.
Rejecting a summary denial of deductions, the Tribunal restored the issue to the AO to verify whether mortgage repayments and other costs were wholly connected with the transfer. Taxpayers were directed to cooperate and file complete evidence.
The issue was whether foreign bank balances funded through LRS could be taxed as unexplained credits. ITAT held that once the source and opening balance are established, section 68 cannot be invoked merely on peak-credit theory.
The issue was whether unsecured loan additions under section 68 could survive based solely on investigation reports and third-party statements. ITAT held that without independent enquiry and nexus to seized material, such additions are unsustainable.
The ITAT held that earning significant exempt dividend income necessarily involves indirect administrative expenses. In the absence of separate books, the AO rightly applied Rule 8D to compute disallowance.
The issue was whether penalties under sections 271D and 271E apply to cash dealings of a credit society with its members. ITAT held that genuine, audited member transactions supported by reasonable cause are protected under section 273B.
The issue was whether demonetisation-era deposits could be taxed despite admitted prior withdrawals. ITAT held that when withdrawals are genuine and the occasion is real, section 69A cannot be applied on presumptions.
The ITAT ruled that section 151 approval must strictly correspond to the recorded reasons for reopening. Any factual inconsistency reflects non-application of mind and collapses the reassessment at inception.
