ITAT Kolkata held that an addition cannot be sustained solely on a survey statement under Section 133A. Proper verification of stock and business records is required before treating income as undisclosed.
ITAT Delhi held that an addition under Section 69C is invalid if it is not based on the allegations in the show-cause notice. The AO cannot exceed the notice, and procedural fairness is mandatory.
ITAT Delhi ruled that sales already recorded in books and accepted under GST cannot be treated as unexplained income under Section 68 without independent verification. No addition can be made solely on untested statements.
ITAT Delhi held that Section 14A cannot be applied when no exempt income is earned, deleting a ₹1.24 crore disallowance. The Tribunal also condoned a 99-day filing delay due to reasonable cause.
ITAT Delhi ruled that validly filed Form 10-IC ensures eligibility for Section 115BAA concessional tax rate. Key takeaway: timely filing secures lower corporate tax in subsequent years.
Tribunal upholds disallowance of ₹76 lakh paid for regularizing building deviations, ruling such compounding fees are penalties under Section 37(1) and not deductible.
Tribunal ruled that amendments to Section 11(3) of Income Tax Act are prospective. Accumulated charitable funds utilized within permitted 5+1 years cannot be taxed, overturning prior additions.
The Tribunal dismissed Revenue appeals for AYs 2006-07 and 2007-08 as the corporate debtor is under CIRP. Section 14(1) moratorium bars all proceedings, ensuring compliance with the Insolvency and Bankruptcy Code.
The AO reopened the assessment relying on external investigation without verifying facts, misclassifying the advance as unexplained income. Tribunal dismissed Revenue appeal and confirmed CIT(A) order.
ITAT Delhi allowed the appeal after noting the CIT(A) ignored a revised Tax Audit Report proving timely PF/ESI payments. Key takeaway: revised audit reports must be considered before confirming disallowances under Section 36(1)(va).
