The ITAT held that disallowance under Section 36(1)(iii) requires factual verification of business purpose. Interest-free loans to group entities were sent back for fresh examination.
The ITAT held that unrecorded sales cannot be taxed in full under Section 69A. Only the profit element at a reasonable GP rate is assessable as business income.
The ITAT held that reassessment based purely on an Investigation Wing report, without the Assessing Officer forming an independent belief, is invalid. Copy-pasted reasons failed to establish a live link between material and escapement of income.
The ITAT held that Rule 8D cannot be invoked without first recording a clear dissatisfaction with the assessee’s working based on accounts. Mechanical application of the rule, without identifying specific expenditure linked to exempt income, was ruled invalid.
The ITAT held that filing Form 10B on the extended due date, especially during COVID-19 relief periods, cannot by itself defeat Section 11 exemption. Procedural delay cannot override substantive compliance.
Chennai ITAT held that dismissing appeals as non-maintainable was erroneous. Orders giving effect to appellate directions retain their character as assessment orders.
The question was whether the extended ten-year window under Section 153C could be invoked. The Tribunal held that where the satisfaction note shows escaped income below ₹50 lakh, the extended limitation is unavailable.
The ITAT noted that cash-flow statements showing withdrawal–redeposit nexus were not examined. Non-consideration of material evidence warranted remand.
The ITAT held that a notice under Section 143(2) issued by a non-jurisdictional officer is invalid. Such a defect strikes at the root of the assessment and cannot be cured.
The issue was whether handwritten lists and affidavits of relatives were sufficient to explain cash deposits. The Tribunal ruled that self-serving documents without independent corroboration carry no evidentiary value under PMLA.
