Adjustments made through CPC were not finally upheld where the assessee raised a valid factual plea on timing of salary payment. The ruling highlights that mechanical disallowances must give way to proper verification.
The Tribunal upheld deletion of unsecured loan additions after finding that the lenders identity, bank trail, and reserves were established. Low declared income alone was held insufficient to treat the credits as unexplained.
Despite non-compliance during assessment, the Tribunal upheld deletion of additions where facts showed only renewal of deposits. Ex-parte proceedings do not justify treating old FDs as unexplained investments.
The issue centred on whether chilling is merely cooling or a technical process. The Tribunal held that chilling involves scientific tests and preservation steps, constituting processing under the Act and justifying the deduction.
The assessee relied on deemed payment after transferring employee dues to another entity. The Tribunal ruled that section 43B recognises only real payment and set aside the relief granted by the appellate authority.
The Assessing Officer treated all cash deposits as unexplained income under Section 115BBE. The Tribunal held that deposits prima facie represented IOC sales and required factual verification before any addition.
The dispute concerned whether transfer through a release deed amounted to a taxable sale and justified loss claims. The Tribunal remanded the matter, directing verification of books to examine the genuineness of the claimed loss.
The issue was whether revision under section 263 could be invoked when the Assessing Officer had accepted a legally possible view. The Tribunal held that where two views exist and the AO adopts one, the order is neither erroneous nor prejudicial.
The decision clarifies that voluntary admission and taxation of income post-search does not ipso facto warrant penalty. Absence of contumacious conduct weighed against the Revenue.
The Assessing Officer inferred undisclosed loans by applying a notional interest rate to declared interest income. The Tribunal ruled that additions under section 69B cannot rest on assumptions ignoring the business model.
