The Tribunal ruled that Section 69A applies only when the assessee is found to be the owner of money or assets. Mere suspicion or digital communication cannot replace proof of possession or ownership.
The issue was whether purchases recorded by the assessee were genuine. The Tribunal held that seized Tally data and statements proved bogus purchases, justifying full addition.
The ITAT ruled that limitation begins when seized material is handed over to the assessing officer of the non-searched person. The key takeaway is that procedural safeguards apply even in search-related cases.
The Tribunal found that lower authorities failed to follow binding coordinate bench decisions on comparability. The case was sent back for re-determination in accordance with law.
The ITAT ruled that accumulated building funds carried forward from previous years are not taxable in the year under scrutiny. The decision reinforces that taxation must align strictly with the year of receipt.
The tribunal held that cash deposits during demonetisation cannot be treated as unexplained income when supported by audited books and stock records. Mere suspicion or surrounding circumstances cannot override accepted accounts.
A single approval was granted for multiple years without examining seized material or draft orders. The Tribunal ruled that such omnibus approval vitiates proceedings under Sections 153A/143(3).
The tribunal held that merely declaring a low net profit rate cannot justify reopening under Section 147. A valid reassessment requires tangible material and a live nexus with income escapement.
The tribunal held that recomputation of deductions under Sections 36(1)(viia)(c) and 36(1)(viii) involves a debatable legal issue. Such matters cannot be corrected through Section 154 rectification proceedings.
The Tribunal held that reopening AY 2012–13 after a post-2021 search was barred by limitation. Applying Supreme Court guidance, it ruled that older limitation periods protect concluded assessments from retrospective reopening.
