The tribunal held that addition under Section 69C is not valid where expenditure is properly recorded and the source is explained. The key takeaway is that documented transactions through banking channels cannot be treated as unexplained.
ITAT Mumbai held that development fees collected from passengers was earmarked for capital expenditure towards modernisation and development of airport infrastructure and therefore the same could not be treated as revenue income of the assessee.
The Tribunal held that an assessment order passed in compliance with DRP directions cannot be revised under Section 263. It clarified that such orders are not erroneous as the Assessing Officer is bound by DRP’s binding instructions.
The Tribunal ruled that additions under Section 69 cannot be sustained when based solely on third-party statements and unverified electronic data. It emphasized the absence of independent evidence and upheld the taxpayers denial of cash payments.
The Tribunal dismissed appeals after the assessee failed to appear despite multiple notices. Lack of participation led to confirmation of additions made by tax authorities.
ITAT confirmed that the amended 60% tax rate under Section 115BBE applies prospectively from April 2017 onwards. For earlier transactions, only the 30% rate applies, safeguarding taxpayers from retrospective burden.
ITAT ruled that the amendment requiring aggregation of consideration under Section 194-IA applies only from October 2024. For earlier years, TDS applicability must be determined individually per buyer-seller transaction.
In the absence of proper compliance with Section 65B and failure to establish a clear chain of custody, the digital evidence relied upon by the Revenue lacked legal admissibility and evidentiary value.
The Tribunal found inconsistency between payment date and share allotment date, raising doubts about the transaction. It held that these factual issues require verification. The matter was remanded to the AO for fresh examination.
Tribunal held that GST-based turnover differences cannot be taxed again when income was already recorded in prior years and notional interest recognized under IND-AS cannot be taxed unless it actually accrues.
