ITAT Bangalore quashed Sec.263 revision, holding AO had examined Model House and ₹9.68 cr expenses in detail; mere change of opinion cannot justify revision.
ITAT Bangalore quashed reassessment for AY 2017-18, holding notice issued on 12-04-2024 time-barred under first proviso to Sec.149(1), despite prior 148A proceedings.
The ITAT Bangalore held that where incriminating documents relating to an assessee are found during a search conducted on another person, the assessment must be framed under Section 153C and not under Section 143(3).
The ITAT Bangalore held that cash received as part of sale consideration for immovable property does not automatically attract penalty under Section 271D if reasonable cause is established under Section 273B.
The ITAT Bangalore held that penalty under Section 271FAA cannot be imposed mechanically where delay in filing the correction statement of financial transactions (Form 61A) is caused by genuine technical and administrative difficulties.
The ITAT Bangalore held that once an Order Giving Effect (OGE) is passed under section 143(3) r.w.s. 254, the Assessing Officer cannot issue a second order for the same assessment year. The Tribunal declared the second OGE non-est and without jurisdiction, dismissing the Revenue’s appeals.
The Tribunal held that where accounts are mandatorily auditable under another law, the extended deadline applies and deduction cannot be denied as time-barred.
The Tribunal upheld deletion of a 30% ad hoc disallowance, holding that expenses cannot be rejected without identifying concrete defects or conducting proper verification.
ITAT ruled that exemption under Section 10(5) does not extend to foreign travel, following the binding Supreme Court decision. Consequently, non-deduction of TDS attracted penalty under Section 271C.
The alleged unexplained investment was based only on third-party statements and seized digital data. In absence of receipts, confirmations, or admission by the assessee, the addition of ₹50 lakh was deleted.
