ITAT Raipur held that reassessment proceedings were invalid where documents and information forming the basis of reopening under Section 148 were withheld from the assessee.
The Tribunal ruled that recording satisfaction under Section 153C is not a mechanical exercise and must clearly establish the relevance of seized material to the assessee’s income.
The Kolkata ITAT held that a commercial loan repaid within the same financial year along with interest and TDS compliance could not be treated as a bogus accommodation entry under Section 68. The Tribunal ruled that documentary evidence and banking transactions established the genuineness of the loan.
The ITAT Visakhapatnam reduced a penalty under Section 271(1)(b) from Rs.30,000 to Rs.10,000 after treating non-compliance with three notices under Section 142(1) as a single default. The Tribunal granted partial relief while holding that the assessee failed to establish reasonable cause for non-compliance.
ITAT Indore held that Section 54 exemption cannot be denied merely for failure to deposit capital gains in the Capital Gain Deposit Scheme. The Tribunal ruled that actual investment in a new residential house within the prescribed two-year period satisfies the substantive requirement.
The Delhi ITAT held that opening balances of unsecured loans cannot be treated as unexplained cash credits under Section 68 when no fresh funds were received during the relevant year. The Tribunal deleted additions after finding that the Assessing Officer wrongly included brought-forward balances.
The Tribunal held that mere disallowance of deduction claimed under Section 80GGC does not automatically amount to misreporting of income. It deleted the penalty as there was no evidence of false particulars or fabricated documents.
The Tribunal held that the enhanced exemption limit of ₹25 lakh under CBDT Notification No. 31/2023 applies to leave encashment claims under Section 10(10AA)(ii). Full exemption of ₹10.15 lakh was allowed to the retired SBI employee.
The Tribunal held that unsigned documents and Tally entries seized from a developer’s premises cannot justify additions without corroborative evidence. It ruled that no addition can survive merely on third-party material lacking proof of actual cash movement.
The Tribunal ruled in favour of the assessee after noting that audited financials, PAN, bank statements, ITRs, confirmations, and MCA records of lenders were furnished. The ruling reinforces that documentary evidence can successfully rebut allegations of bogus loans.
