ITAT rules that reliance on remand report from a different year is invalid, restoring matter to Assessing Officer for AY 2012-13.
Detailed seized agreement and subsequent sale deed considered strong corroboration. Addition under Section 69A sustained in search-based reassessment.
Tribunal holds that working capital impact must be examined by the TPO when comparables are selected by the Department. If adjustment is granted, no separate interest addition is warranted.
The Tribunal ruled that interest could not be disallowed when ample interest-free funds existed and no link was shown between overdraft borrowings and partners’ drawings. The key takeaway is that presumption of utilisation of own funds applies when mixed funds are available.
The Tribunal held that reassessment could not stand because the recorded reasons pertained to a different assessment year. The reopening was invalid, and all related additions were rendered infructuous.
The Tribunal agreed with the CIT(A) that penalty cannot continue after the underlying addition ceases to exist. The ruling highlights strict adherence to the principle of dependency between quantum and penalty.
ITAT held that AYs 2011-12 and 2012-13 were time-barred since the 10-year window must be computed from the date of recorded satisfaction. The ruling reaffirms that out-of-range years cannot be assessed under 153C.
ITAT held that cash deposited during demonetization was fully backed by prior withdrawals exceeding ₹47 lakh. The ruling confirms that demonstrated cash availability defeats Section 68 additions.
Tribunal held that AY 2010–11 was beyond the statutory 10-year window, making the 153A assessment invalid. Time-barred years cannot be revived under extended search assessments.
Tribunal held that ownership records alone cannot justify agricultural income; absence of Khasra and produce-sale evidence required remand. Cultivation must be proved with proper documentation.
