ITAT allowed additional evidence filed by the legal heir and remanded the matter to the AO for verification. The key takeaway is that justice requires giving opportunity where evidence was earlier unavailable.
The Tribunal noted that the assessee provided affidavits, bank statements, and financials of contributors. The addition was deleted as the source stood satisfactorily explained.
The tribunal ruled that failure to strike off irrelevant portions in penalty notice makes it legally defective. Such ambiguity invalidates the entire penalty levy.
The Tribunal held that audited accounts cannot replace documentary evidence for claiming application of income. The case was remanded for fresh verification.
The Tribunal found that the AO relied only on general information without corroborative material. The ruling emphasizes that suspicion cannot replace proof in tax proceedings.
The tribunal ruled that revisionary powers cannot be exercised without questioning the statutory approval under Section 153D. Absence of such examination renders Section 263 action invalid.
The notice issued after the permissible window calculated under TOLA and judicial rulings was held void. The case highlights strict adherence to limitation timelines.
The Tribunal ruled that supplying only a summary of reasons is insufficient in law. The failure to furnish recorded reasons vitiated the entire reassessment.
The tribunal held that penalty for non-appearance cannot be sustained when reasonable cause exists. Ignorance of proceedings and factual circumstances justified relief.
The High Court held that once the assessee failed to explain the source, addition was justified only to the extent of cash actually seized. It ruled that the AO cannot arbitrarily add a higher amount than the proven seized sum.
