The Tribunal held that penalty under Section 271(1)(c) cannot be imposed when additions are made on an estimated basis. It upheld deletion of penalty, emphasizing absence of concrete evidence of concealment.
The Tribunal clarified that filing of original return is not mandatory for claiming exemption under Section 54. It directed verification of conditions and allowed relief if eligibility is established.
The Tribunal held that additions based solely on third-party statements and Excel sheets are unsustainable without independent evidence. It emphasized that denial of cross-examination violates natural justice and invalidates the addition.
ITAT Mumbai deletes Section 69 additions holding that third-party excel sheets and statements without corroborative evidence lack evidentiary value. Reopening based on unverified data and denial of cross-examination violates natural justice; entire additions quashed.
The case examines whether penalty applies when a deduction claim is disallowed. ITAT held that full disclosure and bona fide claim prevent penalty under Section 271(1)(c).
The Tribunal held that reopening an assessment on identical material already examined is invalid. It ruled that reassessment cannot be used to revisit concluded issues without fresh evidence.
The case examined whether minor valuation differences can trigger taxation under Section 56(2)(x). ITAT held that differences within 10% fall within permissible tolerance. The ruling protects genuine transactions from arbitrary additions.
The case addressed whether income can be corrected without filing a revised return. ITAT held that genuine computational errors can be rectified through revised computation during assessment. The ruling prioritizes accurate income over procedural technicalities.
The case examined whether CSR expenses can qualify for deduction despite Section 37 disallowance. ITAT held that Section 80G operates independently and allows deduction for eligible donations. The ruling clarifies dual treatment of CSR spending.
The case examined whether old share capital can be taxed due to ROC strike-off of a shareholder. ITAT held that Section 68 applies only to credits in the relevant year. The ruling clarifies that historical transactions remain valid.
