The Tribunal held that reassessment beyond four years is invalid when the AO fails to show how the assessee withheld material facts. The AO merely copied Investigation Wing inputs without independent reasoning. The entire reassessment was declared void for violating the proviso to Section 147.
The Tribunal held that cash deposits are explained when supported by corresponding withdrawals, even without precise mapping. Once the assessee shows availability of funds, the onus shifts to the AO to rebut the explanation. The addition under Section 69A was deleted in full.
The Tribunal held that reopening based on Section 50C was unsustainable because the provision applies only to sellers, not purchasers of property. With the very foundation of reassessment failing, the addition based on circle-rate difference was deleted. The ruling underscores that incorrect legal assumptions cannot justify reopening under Section 147.
The Tribunal deleted the Section 68 addition after finding no material linking the assessee to any accommodation-entry scheme. All documentary evidence—demat records, broker notes, and banking channels—supported genuine share transactions. The ruling reiterates that suspicion or probability cannot override verified evidence.
The ITAT held that cash deposits during demonetisation could not be taxed u/s 68 when all sales were recorded, verified, and supported by stock and VAT records. Since books were audited, accepted, and showed no defect, the addition of ₹12.20 crore based on mere averages was unsustainable. The ruling confirms that documented cash sales cannot be taxed again as unexplained cash credit.
ITAT ruled that reopening was bad in law as reasons cited property purchases, while additions related to cash credits—showing no live nexus. The case reaffirms that reassessment must be based on specific, relevant material.
Delhi ITAT held that non-filing of Form 10B is a curable defect and the assessee must be given an opportunity under section 139(9). Gross receipts cannot be taxed in entirety if exemptions fail.
The ITAT held that cash deposits recorded in books and from legitimate business sales during demonetisation cannot be treated as unexplained under Section 69A. Entire addition of ₹45.23 lakh was quashed.
The Delhi ITAT upheld deletion of ₹2.57 crore TP adjustment, confirming that mere margin variations do not trigger 80IA(10) without evidence of profit manipulation. Revenue’s appeal dismissed.
The tribunal dismissed the revenue’s appeal, holding that the assessee was entitled to ₹2.36 crore deduction under Section 54F. Evidence showed only one residential property purchase, and farmhouse classification did not disqualify the claim.
