The Tribunal observed that rejection of audited books and disallowance of labour charges must be backed by concrete defects. Purely ad-hoc estimations based on minimum wages were held improper.
The Tribunal held that GST paid during the relevant year is allowable under Section 43B even if it relates to an earlier period. Since the amount was actually paid and not claimed earlier, disallowance was unjustified.
The Tribunal found that notices issued manually by the jurisdictional officer contravene the faceless reassessment framework. There is no concurrent jurisdiction between faceless and jurisdictional officers. Any reassessment initiated this way is invalid from inception.
The Tribunal held that after 29-03-2022, only a Faceless Assessing Officer is empowered to issue notices under Section 148. Notices issued by a jurisdictional officer were declared void, vitiating the entire reassessment.
The Tribunal partly allowed the Revenue’s appeal by holding that interest incurred on borrowings used for project development must be capitalised. Absence of evidence showing alternative use of funds justified capitalization.
ITAT Bangalore rules that Section 80P deductions cannot be claimed if the return is filed after the due date. The decision reinforces compliance with Section 80AC(ii) and aligns with Madras HC precedent.
ITAT Bangalore directs reassessment with full hearing for an agriculturist after procedural lapses in notices and missed hearings. The ruling emphasizes the importance of fair opportunity under Sections 148 and 144B.
ITAT Visakhapatnam held that unexplained cash credit under Section 68 must be netted off against business income to prevent double addition. The ruling ensures accurate assessment and fair taxation.
Cash deposits were rightly taxed as unexplained money when the assessee failed to discharge the primary burden of proof. Absence of contemporaneous evidence defeats claims of redeposit of cash.
The ruling clarifies that Section 153(3)(ii) operates as an exception to the normal limitation framework. When assessments are made to give effect to appellate directions involving special audits, no fixed time limit applies.
