ITAT held that where interest-free funds exceed advances, a presumption arises that such advances are made from own funds. Disallowance under section 36(1)(iii) was deleted as no nexus with borrowed funds was proven.
The Tribunal ruled that section 44ADA applies only to specified professions and cannot be invoked for business income covered under section 44AD. Arbitrary substitution of a higher rate by the AO was held unsustainable.
The case involved estimated addition on agricultural income and dismissal of appeal for non-prosecution. ITAT held such dismissal invalid and ruled that arbitrary estimation without evidence cannot sustain.
The dispute concerned alleged bogus agricultural income taxed as unexplained money under Section 69A. The Tribunal set aside the addition and directed the AO to re-examine evidence before reaching a conclusion.
The issue was whether demonetisation cash deposits can be taxed as unexplained credits solely due to use of SBN. The ITAT held that proper explanation and records negate automatic addition under section 68.
The case examined if failure to conduct audit permits arbitrary profit estimation. The ITAT ruled that absence of audit alone cannot justify 8% estimation when books are maintained and not rejected.
The case involved addition for alleged on-money payment based on search findings of a builder. The ITAT ruled that absence of corroborative evidence and denial of cross-examination makes the addition unsustainable.
The Tribunal ruled that revision under Section 263 requires examination of approval granted under Section 153D. Without establishing any defect in such approval, the assessment cannot be termed erroneous. The decision limits arbitrary revision powers.
The Tribunal held that additions cannot be sustained merely on third-party Excel sheets and statements. It ruled that absence of independent evidence and denial of cross-examination renders such additions invalid.
The Tribunal ruled that incorrect invocation of Section 69A does not invalidate the addition. Since the loan was found to be an accommodation entry, it was sustained under Section 68. The decision emphasizes substance over technical defects.
