The issue was whether cash deposited during demonetisation could be taxed as unexplained money. The Tribunal held that prior withdrawals from the bank sufficiently explained the deposits, warranting deletion of the addition.
The tribunal refused to admit a fresh legal challenge to reassessment raised for the first time. However, it remanded the revenue-difference addition for fresh adjudication due to natural justice concerns.
The case addressed whether an authority can reject registration before completion of parallel statutory processes. The Tribunal held that hurried rejection was unjustified and directed de novo adjudication.
Payments made pursuant to allotment confer valuable property rights. Their relinquishment through an agreement to sell amounts to a statutory transfer, entitling the assessee to compute gains or losses under capital gains.
The tribunal ruled that cash deposits sourced from recorded cash sales and bank withdrawals were genuine. It held that partial, ad-hoc additions without rejecting books of account are unsustainable.
The Tribunal held that an appeal should not be rejected merely due to long delay when sufficient cause is shown. It ruled that technicalities cannot defeat substantial justice and restored the matter for decision on merits.
The tribunal held that cash deposits were largely explained through earlier withdrawals and business receipts. Only an estimated 10% addition was sustained, and harsh taxation under section 115BBE was ruled out.
Reopenings based on assumptions, conjecture, or generalized allegations were struck down. The ruling reiterates that reasons must show tangible material, application of mind, and a live nexus with escaped income.
Where updated cash books explained the cash found and no defects were pointed out, additions under section 69A were held unsustainable. Substantiation with regular books prevailed over search-time snapshots.
The Tribunal refused to send the matter back for valuation after finding a clear statutory breach. The addition was deleted outright, reinforcing strict compliance with valuation provisions.
