The Tribunal deleted ₹8,82,278/- addition after assessing income under two heads. Initially, the A.O. and CIT(A) had sustained the addition as unexplained. Key takeaway: all income heads must be considered during reconciliation after a search.
The ITAT set aside CIT(E) orders denying Section 12A registration and 80G approval due to non-receipt of document requests, allowing the trust a fresh opportunity to comply.
Parasnath Fuels Pvt. Ltd. Vs DCIT (ITAT Dehradun) Rule 29 Rescues Assessee- Loans Need Fresh Look: ITAT Admits New Evidence, Sends Rs.90 Lakh Addition Back to AO Assessee appealed against NFAC order dated 08.10.2024 sustaining addition of Rs.90,00,000/- u/s 68 r.w.s 115BBE towards unsecured loans from M/s Yogya Shippings Pvt. Ltd. (Rs.50 lakh) & M/s […]
The Tribunal condoned the delay and held that the appeal could not be dismissed in limine. CIT(A) must issue a reasoned order on merits under Section 250(6).
The Tribunal condoned a 28-day delay in filing the appeal due to reasonable cause. The assessee had failed to comply with notices and did not provide evidence for deductions. All additions made by the Assessing Officer, including capital gains and salary income, were upheld.
The Tribunal directed the Assessing Officer to verify the assessee’s turnover before applying corporate tax. If turnover for FY 2018-19 is under ₹400 crore, the tax rate must be computed at 25% instead of 30%.
The Tribunal allowed the appeal for AY 2010-11, noting that AO failed to verify agricultural income and bank deposits properly. CIT(A) also overlooked key evidence. The case is remitted for fresh assessment to ensure proper scrutiny.
The Tribunal quashed penalties for AYs 2009-10 and 2012-13, holding that show-cause notices must clearly specify the charge under Section 271(1)(c). Vague notices violating natural justice cannot sustain penalties. This reinforces the strict requirement for specificity in penalty proceedings.
Tribunal held that CIT(A) erred in rejecting the appeal despite Supreme Court–mandated limitation extensions. COVID-19–related delays must be liberally condoned when reasonable cause is shown.
The Tribunal clarified two key issues: depreciation on assets received in demerger and PF/ESI contribution disallowances. Revenue’s appeal was dismissed for AY 2017-18, while the assessee’s appeal for AY 2024-25 was partly allowed. This decision reinforces consistency in asset-related claims and practical application of Section 36(1)(va).
