The Tribunal held that AO’s ad-hoc disallowances were unsustainable as he failed to verify evidence. CIT(A) examined detailed ledgers and explanations, deleting unsupported additions. The appeal highlights the importance of evidence-based assessments over arbitrary estimates.
ITAT Agra held that reassessment under Section 144 by JAO is valid even though faceless procedure under Section 144B was generally applicable. The CBDT Circular of 17.03.2022 provided relaxation for cases with expiring limitation. CIT(A)’s non-est finding was set aside, ensuring compliance with procedural exceptions.
ITAT Agra held that additional evidence proving the land’s distance from municipal limits is crucial for reassessment under Section 56(2)(vii). The case was remanded to AO for de novo verification, allowing the assessee to file further supporting documents.
The Tribunal found that the AO failed to establish any bogus purchase or sale since the assessee never handled the goods and only received net surplus. Identical findings in earlier years compelled the ITAT to delete the same addition again. The takeaway is that established business patterns cannot be arbitrarily recharacterized as accommodation entries.
The Tribunal admitted additional evidence such as partnership deeds, royalty ledgers, and source-wise cash deposit mapping. Since AO never verified these materials, the addition under Section 69A could not be sustained. The issue was restored for proper factual examination.
The Tribunal ruled that when no new loans are borrowed or granted, taxpayers need not re-prove nexus annually. Interest paid deduction under section 57(iii) was restored.
ITAT Raipur ruled that cash deposits made by an advocate on behalf of clients cannot be treated as unexplained money under Section 69A. The AO and CIT(A)/NFAC conducted no inquiry and ignored over 100 supporting challans. This reinforces the principle that evidence and factual verification are essential before making additions.
ITAT Raipur set aside a Rs. 14.73 lakh addition under Section 69C after finding the CIT(A) misinterpreted the assessee’s wife’s financial capacity, affirming proper documentation supports legitimate expenditure.
Disallowance of ₹10.2 lakh on bank interest by the AO was reversed by ITAT, relying on favorable Karnataka HC rulings. The Tribunal confirmed that interest on surplus funds deposited in co-operative banks counts as business income eligible for 80P(2)(a)(i) deduction.
ITAT Bangalore held that disallowances under section 36(1)(va) for employee PF/ESIC contributions before AY 2021-22 were unsustainable, as Finance Act 2021 amendments are prospective. The Tribunal directed AO to delete additions, safeguarding assessee from retrospective impact.
