The AO compared per-location payments to different vendors to allege excessiveness. The Tribunal held that such comparisons lack statutory backing when parties are unrelated and services differ in nature and complexity.
The AO completed assessment under Section 144 after alleged non-compliance, but failed to prove valid service of notice under Section 148. The Tribunal ruled that absence of jurisdiction renders the entire proceedings null.
The PCIT questioned deduction under Section 80JJAA and CSR expenses but failed to record specific findings. The Tribunal held that absence of independent verification and reasoning renders the Section 263 order invalid.
The Tribunal held that reopening beyond three years is impermissible where alleged escaped income is below ₹50 lakh. Since the notice violated Section 151, the reassessment was quashed.
The Tribunal ruled that since the assessment was legally correct when passed, invoking Section 154 after a later Supreme Court decision was impermissible. The addition was consequently deleted.
The Tribunal deleted ₹35.22 lakh added under Section 68 for cash deposits during demonetisation. It held that audited books, recorded cash sales, and sufficient cash balance fully explained the deposits.
The Tribunal held that alleged on-money addition based solely on third-party loose papers is unsustainable. In absence of independent evidence linking the assessee to unaccounted payment, the addition was deleted.
The Tribunal ruled that invoking Section 68 on member deposits of a cooperative society was unjustified. Proper books, cash records, and member-wise details were ignored by the AO.
The Tribunal upheld deletion of ₹3.67 crore added as unexplained cash credit from Singapore art exhibition sales. It held that detailed export, remittance, and bank evidence fully established the genuineness and source of funds.
Rejecting reliance on time lapse and regulatory issues, the Tribunal held that a trading liability remains valid unless actually extinguished. The addition under Section 41(1) was therefore deleted.
