The ITAT held that mere disclosure of undisclosed income during search is insufficient for immunity under Section 271AAA unless the assessee substantiates the manner in which such income was derived.
The ITAT held that CSR expenditure disallowed as business expenditure under Section 37(1) can still qualify for deduction under Section 80G if statutory conditions are satisfied. Revision under Section 263 was accordingly quashed.
The ITAT held that unverified third-party excel sheets without corroborative evidence cannot justify additions under Sections 69 or 69A. The Tribunal observed that mere electronic entries amount to dumb documents unless independently verified.
The ITAT ruled that accepted sales necessarily imply corresponding purchases, even if sourced through the grey market. The addition was therefore restricted to estimated profit instead of the full purchase amount.
The Tribunal held that the AO wrongly aggregated actual property value and stamp duty valuation of the same transaction to invoke extended limitation under Section 149(1)(b). The reassessment notice for AY 2015-16 was declared time-barred and without jurisdiction.
The Mumbai ITAT held that no separate addition for alleged bogus purchases can be made where the assessee has already disclosed a higher gross profit on disputed transactions. The Tribunal relied on Bombay High Court rulings limiting additions only to differential GP.
The ITAT Delhi held that contractual receipts reflected in the PAN of a dissolved partnership firm could not be taxed again when they were already disclosed in the proprietorship concern of the surviving partner. The Tribunal ruled that such addition would amount to double taxation.
ITAT Indore set aside the ex parte appellate order after noting that the assessee had died and the legal heirs could not effectively pursue the proceedings. The Tribunal granted one final opportunity for fresh adjudication on merits.
The ITAT Delhi held that the upload date of DRP directions on the ITBA portal must be considered for computing limitation under Section 144C(13). Since the final assessment order was passed beyond the prescribed period, the assessment was quashed as time-barred.
ITAT Delhi held that amounts received from encashment of bank guarantees could not be treated as taxable income where the assessee acted only as custodian of government money. The Tribunal followed earlier rulings in the assessee’s own case and dismissed the Revenue’s appeal.
