The case addresses whether reassessment is valid when approval is granted by the wrong authority. ITAT held that sanction under Section 151 is jurisdictional and must be from the correct authority. The entire reassessment was quashed for non-compliance.
The case examines whether estimated expense disallowances can be made without rejecting books of account. ITAT held such additions invalid, emphasizing that Section 145(3) rejection is a prerequisite. The ruling protects taxpayers from arbitrary disallowances.
The case addressed whether agricultural income claims can be rejected due to lack of initial evidence. ITAT held that substantial supporting documents cannot be ignored and remanded the matter for fresh verification. The ruling emphasizes fair consideration of evidence.
Addition under Section 68 could not be sustained where assessee has established the genuineness of a Non-banking financial company (NBFC) investor, and the AO failed to rebut such evidence or trace any money trail linking the assessee to the invested funds.
ITAT Mumbai rules that Section 11(5) investment shortfall of earlier years cannot be taxed in the current year, holding amendment prospective. Only current year violation is taxable, restricting addition to ₹5 lakh and deleting ₹1.34 crore.
ITAT held that penalty cannot be imposed where incorrect return was due to consultant’s misconduct. The ruling highlights that bona fide mistakes with voluntary tax payment negate penalty.
The Tribunal held that deduction claims should not be rejected for technical non-compliance. It emphasized that substantive provisions prevail over procedural requirements.
ITAT held that interest earned on bank deposits is taxable and not covered by the principle of mutuality. The ruling confirms that dealings with third parties break mutuality protection.
The Tribunal admitted a new legal ground and held that jurisdictional defects can be raised at any stage. It quashed the assessment as the initial notice itself was issued without authority.
ITAT held reassessment invalid as it was based on already examined facts without fresh material. The ruling reinforces that reopening on mere change of opinion is not permissible.
