The Tribunal emphasized that even pending SLPs cannot override the statutory 10-year limitation for assessments. Revenue’s attempt to reopen AY 2010-11 under Section 153A was rejected, upholding the CIT(A)’s quashing of the order.
The Tribunal held that exemption under Section 13A does not automatically relieve the payer from deducting TDS on interest paid to political parties. It found the earlier High Court ruling relied upon by CIT(A) to be distinguishable. The matter was remitted to the AO to test compliance with the first proviso to Section 201.
ITAT Hyderabad held that verifying documents of only one party cannot substitute verification of all transactions under Section 69C. The matter is remanded to the AO for de novo scrutiny of purchase bills, ledger accounts, transportation memos, and payment proofs for all thirteen parties.
The Tribunal held that the CIT(A) acted inconsistently by condoning delay in the quantum appeal but refusing the same in penalty appeals. Since sufficient cause existed and was already recognized, delay in all penalty appeals was condoned. Penalty matters were restored to the AO for reconsideration.
The Tribunal held that CIT(A) misinterpreted a VSVS 2020 declaration for penalty as covering quantum, dismissing the appeal without considering merits. The order was set aside, and the matter remanded for de-novo adjudication. Quantum issues must be assessed independently of VSVS for penalties.
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.
