The Tribunal ruled that mere observations about cash transactions are insufficient to levy penalty under Section 271D. A specific finding establishing contravention of Section 269SS is mandatory before imposing penalty.
The Hyderabad ITAT held that only the actual period lost during the limitation period can be excluded under Explanation-1 to Section 153. It ruled that the assessment order passed beyond the permissible period was invalid.
The Tribunal ruled that the word purchase under Section 54 must receive a liberal and purposive interpretation. Genuine investment in a residential property within the prescribed period can qualify for exemption even without a registered conveyance deed.
The Kolkata ITAT held that the Assessing Officer cannot make arbitrary 10% expense disallowances without identifying specific defects or inflated claims. The Tribunal upheld deletion of ₹2.23 crore addition after finding the disallowance was based purely on guesswork and suspicion.
The Tribunal held that entries found in third-party ERP software during a search cannot alone justify unexplained investment additions under Section 69. Absence of corroborative evidence led to deletion of the entire addition.
The Tribunal held that reassessment proceedings were invalid where the Assessing Officer ignored the assessees detailed response and documentary evidence. ITAT ruled that such action violated principles of natural justice and reflected non-application of mind.
Ahmedabad ITAT held that the Assessing Officer wrongly treated entire business liabilities and receipts as unexplained income. The addition was drastically reduced to estimated profit at 15% of disputed turnover.
The Tribunal held that merely declaring presumptive income under Section 44AD does not exempt taxpayers from explaining massive bank credits. In absence of purchase records, bills, or confirmations, Section 69A addition was sustained.
The Tribunal held that once the income disclosed in the return filed under Section 148 was accepted without any addition, there could be no allegation of under-reporting or misreporting. The entire penalty of ₹4.91 lakh was deleted.
The Tribunal ruled that corpus donations cannot be taxed merely because Section 12AA registration was granted subsequently. Once registration existed before processing of return, exemption under Section 11 could not be denied.
