ITAT ruled that unverified electronic records recovered from a third party do not constitute reliable evidence of cash payments. Additions based solely on such data were deleted.
The Tribunal held that interest earned from deposits with co-operative banks qualifies for deduction under section 80P. Such interest does not lose its character as business income of an eligible co-operative society.
The Tribunal held that receipts already offered under the presumptive scheme cannot be taxed again as unexplained money. Once income is declared under section 44AD and supported by surrounding facts, section 69A has no application.
The Tribunal held that reassessment under section 147 fails when the alleged income escapement cited for reopening is accepted and no related addition is made. Without sustaining the original reason for reopening, jurisdiction itself collapses.
The Tribunal upheld the remand of an ex parte assessment where substantial bank deposits were not supported by any documentary evidence. It held that unsupported explanations cannot replace proof, and fresh verification by the Assessing Officer was necessary.
The Tribunal held that section 50C could not be applied where the sale consideration exceeded the value accepted by the stamp authority. A clerical error in departmental data could not justify substitution of sale value.
The Tribunal held that denial of TDS credit solely on mismatch grounds requires factual verification. The Assessing Officer must examine whether the individuals in whose names TDS was deducted have already claimed the credit.
The tribunal held that assessments selected for limited scrutiny cannot include additions on unrelated issues without formal conversion to complete scrutiny. All such additions were set aside as being without jurisdiction.
The case examined the tax treatment of purchases from alleged accommodation entry providers. The Tribunal held that at best, only the profit element embedded in such purchases can be brought to tax.
The Assessing Officer disallowed interest expenditure in an ex parte order under section 144. The Tribunal ruled that once evidence shows a clear link between interest paid and interest earned, the deduction must be allowed.
