The Tribunal deleted ₹20,00,055 added as unexplained income after finding the transaction was based on mistaken identity. No evidence proved that the assessee received funds from the alleged shell company.
ITAT held that once the concessional tax option under Section 115BAB is exercised in the first eligible year, it automatically applies to subsequent years. Technical defects in later returns cannot defeat the claim.
The Tribunal clarified that passing an order in the name of a non-existent entity is not a mere procedural defect. It held that participation in proceedings does not validate a void assessment.
ITAT ruled that exemption under Section 10(23C)(iiiad) cannot be denied merely because of an incorrect disclosure in the return. Documentary proof of running a school was decisive.
ITAT ruled that without rejecting books of account or disproving sales, addition of aggregate cash deposits is unsustainable. Detailed reconciliations established nexus with business receipts.
The Tribunal deleted addition under Section 69C, holding that payments made by company on behalf of director were properly explained through ledger records and imprest arrangement.
The ruling highlights that mere failure to file return, without concealment or tax evasion, does not automatically attract Section 270A penalty. Bona fide explanation and TDS compliance protected the taxpayer.
Recognizing the 10% tolerance band as a beneficial amendment, the Tribunal applied it retrospectively. The ruling clarifies that minor valuation gaps cannot lead to artificial income additions.
ITAT upheld deletion of additions where assessment was framed under the wrong provision. Since the year fell within the block period of a non-searched person, Section 153C was mandatory.
ITAT ruled that reassessment made pursuant to a quashed Section 263 order has no legal basis. Subsequent additions cannot stand once the revision itself is annulled.
