The ITAT upheld ₹90 lakh addition as the assessee failed to establish genuineness and creditworthiness of the transaction. The ruling emphasizes the burden of proof on taxpayers in cash credit cases.
The ITAT held that the PCIT cannot invoke revisionary powers when the same issue is already pending before the appellate authority. The case involved share transaction additions treated as penny stock.
The Supreme Court declined to recall its earlier order, effectively upholding the High Court ruling that TDS was not applicable on payments for imported Business Information Reports. The decision affirms reliance on consistent AAR rulings.
The Bombay High Court upheld ITAT’s ruling that payments for Business Information Reports did not attract TDS under Section 195. The decision relied on consistent AAR rulings on identical facts.
The Court held that once a resolution plan is approved, prior tax liabilities stand extinguished. Reassessment under Section 148 was therefore unsustainable.
The High Court held that once a resolution plan under IBC extinguishes prior tax liabilities, reassessment cannot be initiated. The notice under Section 148 was set aside. The ruling confirms that extinguished claims cannot be revived through reassessment.
ITAT held that reassessment notice issued after three years without PCCIT approval violates Section 151(ii). The approval taken from PCIT was found insufficient. The ruling confirms that proper authority approval is mandatory for valid reassessment.
ITAT upheld deletion of penalty as the exemption issue was pending before the High Court. The assessee had filed an undertaking under Section 158A. The ruling highlights that penalty cannot be sustained when the core issue is yet to be finally adjudicated.
ITAT remanded the case as authorities failed to determine whether the assessee was a society, trust, or other entity. The eligibility for deduction was not properly examined. The ruling highlights the need for factual verification before denying tax benefits.
The Tribunal held that the assessee failed to substantiate the source of cash deposits during demonetization. Mere disclosure in books was insufficient without proof of genuineness and credibility.
