The Tribunal held that a surrender during survey cannot justify additions without supporting material. Statements under Section 133A lack evidentiary value unless backed by records. Additions based solely on surrender were deleted.
The ITAT held that additional evidence filed under Rule 46A cannot be brushed aside without examination. Since the documents were vital to Section 68 requirements, the matter was remanded for fresh adjudication.
The ITAT held that a trust cannot be faulted for missing a statutory deadline when compliance was factually impossible. The rejection of 80G renewal was set aside and remanded for fresh consideration on merits.
The assessee argued that revision proceedings were vitiated as they followed an audit objection. The ITAT rejected this plea, holding that audit-based information can validly trigger revision if conditions of section 263 are met.
The ITAT held that revision under Section 263 cannot be invoked merely because the PCIT disagrees with the Assessing Officer’s view. Once enquiries are made and explanations accepted, substitution of opinion is impermissible.
The ITAT held that even a small part payment through banking channels before or on the agreement date is sufficient to invoke the provisos to section 56(2)(vii)(b)(ii). Substantial payment or possession is not a statutory requirement.
The Tribunal held that a final assessment passed after the expiry of Section 153 is invalid, even if it follows DRP directions. The is that limitation under Section 153 remains mandatory and cannot be bypassed through the DRP route.
ITAT held that disclosures in an election affidavit cannot, by themselves, justify reopening an assessment. The ruling reinforces that reassessment requires fresh tangible material and a live link to income escaping assessment.
ITAT Pune held that a claim of agricultural income cannot be accepted without supporting records. Complete non-compliance at all stages justified treating the receipts as unexplained income.
ITAT Hyderabad held that an unsigned sale agreement cannot automatically justify higher capital-gains additions. The AO must verify actual receipt of funds before confirming any addition.
