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.
ITAT Bangalore restored ₹4.19 crore claimed as revenue loss to CIT(A) for fresh examination. The Tribunal emphasized that proper assessment under Sections 37(1) and 28 is essential before allowing write-offs.
ITAT Bangalore condoned a 247-day delay in filing appeals caused by email miscommunication and change of accountants. The Tribunal restored Section 80P(2)(a)(i) deductions for cooperative society interest income.
ITAT restored the case to the Assessing Officer to examine jurisdictional defects, evidence, and applicability of section 115BBE. Technical dismissal by the appellate authority was set aside.
SEO Description: The Tribunal ruled that sanction granted by merely stating as per annexure reflects no independent application of mind. Such mechanical approval violates statutory requirements. Consequently, the reassessment proceedings were set aside.
SEO Description: Relying on binding Delhi High Court authority, the Tribunal held that EDC payments require TDS under Section 194C. Non-compliance validly triggered demand and interest provisions.
