he ITAT ruled that an automatic ₹56 lakh 14A disallowance was invalid as the AO failed to record specific satisfaction regarding the assessee’s claim. The Tribunal emphasized that generic reasoning cannot replace case-specific analysis.
ITAT Mumbai quashed ex-parte assessment based solely on AIR entries, directing AO to provide full details so assessee can respond and defend his position.
Tribunal held that an income tax demand raised due to a technical misentry in return must be rectified. Assessing officer erred by retaining 143(1) demand after scrutiny under 143(3).
The ₹8.49 lakh credited for household expenditure from husband was deleted as non-taxable. The unexplained ₹17.80 lakh in the capital account is sent back to the AO for proper verification and opportunity to furnish evidence.
ITAT found that reopening relied on wrong bank deposits, incorrect assessee details, and a mechanical sanction under section 151. The reassessment under sections 144/147 and the ₹15 lakh unexplained cash addition were deleted.
The ITAT found the AO’s valuation incorrect, emphasizing that FMV must be determined on the date of transfer, leading to the restoration of the long-term capital loss for the Assessee.
The Tribunal directed AO to compute Section 14A disallowance only for investments generating exempt income, following Rule 8D. The decision reinforces the need for precise calculation of disallowances against exempt income.
ITAT quashed the reassessments, agreeing with prior ruling that combined approval under section 148B for multiple assessees violates legal requirements.
ITAT Mumbai condoned 75-day delay in filing appeal, recognizing assessee’s illiteracy and reliance on tax consultant, allowing fresh adjudication on merits.
The Tribunal set aside the ex parte dismissal of the AY 2018-19 appeal, restoring the matter to CIT(A) for merits-based hearing. The assessee was allowed to present evidence regarding ₹3.74 crore unexplained investment and estimated profits.
