Tribunal found that the CIT(A) admitted new evidence without AO’s opportunity and remanded the case for re-examination of NRE deposit sources under Section 69.
Tribunal held that a minor delay should not defeat justice and directed CIT(A) to hear the case on merits, citing violation of Section 250(6).
The Tribunal accepted medical reasons for delay, found notice service defective, and set aside a non-speaking CIT(A) order for fresh adjudication under Section 250(6).
Tribunal ruled that disallowance for not filing Form 10 can only apply in the year of default, not later years of utilization. Addition of ₹80 lakh deleted.
The Tribunal held that CIT(A) must decide all grounds, including legality of reopening under Section 147/148. Order remanded for fresh adjudication under Section 250(6).
ITAT ruled that ₹10 lakh deposit in demonetisation period, backed by gifts, savings, and sale of gold, cannot be treated as unexplained under section 69A.
The appellate authority held that additions cannot be sustained solely on external information without independent verification. Bogus purchase claims under Section 69A were deleted.
The appellate authority held that unexplained cash additions under Section 69A require evidence, not mere suspicion. Cash from property sale deposited after ten months was justified and deletion allowed.
ITAT ruled that reassessment under section 147 is valid even if based on an old PAN, as banking and TDS records may reflect its continued use. Ex parte assessment was remanded for proper reconciliation.
The Supreme Court held that revision under Section 263 requires both error and prejudice to revenue. In this case, depreciation claimed by a loss-making entity was tax-neutral, so revision was invalid.
