Lease rentals of ₹2.88 crore from the company’s warehousing complex were rightly classified as income from house property, reversing the AO’s business income classification. This restored the standard deduction of ₹83.38 lakh under Section 24(1).
The Tribunal held that unsecured loans cannot be treated as unexplained when identity, creditworthiness, and genuineness are fully documented. Since the AO ignored evidence and relied only on non-appearance, the addition was deleted.
Since the assessee did not receive notices sent to a wrong email, non-compliance findings were unsustainable. The ITAT directed the Assessing Officer to examine evidence and pass a speaking order after granting a proper hearing
Tribunal ruled that appeals delayed beyond a reasonable period without valid reasons cannot be admitted for consideration under Section 263.
The Tribunal held that notices sent to an incorrect email constituted a valid reason for delay, restored the matter to the AO, and emphasized the need for fair opportunity. Key takeaway: technical lapses in service cannot defeat substantive justice.
Tribunal emphasized reasonable opportunity of hearing and proper consideration of all evidence to resolve disputed reassessment under Section 147/144.
ITAT held that cash deposits during demonetization were explained through duly recorded cash sales supported by VAT returns and stock records. Key takeaway: When books are accepted, cash sales cannot be treated as unexplained.
Tribunal held that a Section 148 notice issued by the Jurisdictional AO after 29.03.2022 is invalid under the faceless reassessment regime. It ruled that only the Faceless AO could issue such notices, vitiating the entire reassessment.
ITAT Delhi held that obtaining sanction u/s 151 from PCIT instead of PCCIT for reopening beyond 3 years invalidates reassessment. Jurisdictional defect renders entire proceedings void.
The Tribunal held that reopening was invalid as the sanctioning authority recorded only a one-word approval. Key takeaway: Mechanical approval without reasoning vitiates jurisdiction under Section 147.
