The appellate orders for AY 2012-13 & 2013-14 were set aside as the deceased assessee was not heard. The legal heir is now allowed to present documents and have the appeal adjudicated afresh.
Tribunal held that identity, creditworthiness, and genuineness of shareholders were proven through documents filed before AO and CIT(A). Since authorities ignored valid evidence, the section 68 addition was deleted.
An addition of ₹1 crore under section 68 was challenged on the ground that the assessee had no opportunity to produce supporting documents. The matter was remanded to the AO for de novo assessment, keeping all contentions open.
The tax authority’s assessment and penalty were set aside as the assessee was not given a fair opportunity to submit documents or Rule 46A application. The court emphasized adherence to natural justice before rejecting section 54F claims.
The ITAT ruled a reassessment under Section 147 invalid because the Assessing Officer failed to issue the mandatory Section 143(2) notice. compliance with notice requirements is crucial for valid reassessment.
The Tribunal held that unexplained money addition cannot stand when the AO ignores direct verification from the bank. Matter restored to the AO to summon the bank and tax only actual interest income.
The Tribunal held that agricultural income cannot be disallowed merely due to a year-on-year increase. Since land ownership, crop details, and receipts were undisputed, the addition was deleted.
The Tribunal condoned a 960-day delay after finding that the assessee’s reliance on VSV settlement and pending rectification was a bona fide cause. It ruled that penalty under Section 271D is independent of quantum proceedings. The penalty appeal was wrongly dismissed as infructuous and has been remanded for fresh decision.
The Tribunal found that a fixed-deposit mismatch caused an unjustified ₹5.33-crore addition. Delay was condoned and the matter was remanded for fresh assessment with proper verification.
The Tribunal accepted that the 7.5% rebate was a pre-negotiated commercial discount and not an unaccounted cash return. As the seized loose sheets were unverified and unsupported by witnesses, the ₹9.06 crore addition failed.
