The Tribunal upheld deletion of addition made on alleged unexplained investment in property. It held that difference between initial agreement value and final sale deed, without evidence of extra payment, cannot justify addition under Section 69.
ITAT Hyderabad refused to condone 632-day delay, dismissing appeal as time-barred, but quashed Section 271(1)(c) penalty for lack of recorded satisfaction in assessment order.
The Tribunal ruled that invoking clause (i) instead of clauses (iii)/(iv) of Explanation 2 was legally incorrect where material belonged to another person. The reassessment proceedings were quashed for non-compliance with statutory procedure.
Section 69C addition of ₹1.10 crore deleted as pen drive data lacked valid 65B certificate; ITAT Hyderabad held third-party digital evidence inadmissible without corroboration.
The Tribunal clarified that mere search under Section 132 does not automatically justify reopening. The AO must demonstrate year-specific escapement of income and follow mandatory approval procedures.
ITAT Hyderabad held that the assessment was barred by limitation under Section 153. Only the actual period lost during search proceedings could be excluded, not the full 180 days.
ITAT Hyderabad remanded the capital gains issue for verification of demolition expenses under Section 48. The Tribunal directed the AO to examine evidence before allowing indexed cost.
ITAT Ahmedabad held that property payments were properly explained with bank records and affidavits. Additions under Section 69 for cash deposit and stamp duty were deleted.
ITAT held that cash loans taken for son’s education were bona fide and supported by evidence. Reasonable cause under Section 273B justified deletion of penalty.
ITAT Ahmedabad held that appellate authorities can entertain fresh legal claims even if not made in the return of income. BSNL VRS-2019 compensation was held exempt u/s 10(10B), and rejection by CIT(A) was set aside.
