The addition was set aside as no cash was found, traced, or shown to be received by the assessee. Mere suspicion or inference cannot substitute proof under section 69A.
The Tribunal held that estimating commission income without corroborative evidence is unsustainable. Audited accounts and consistent interest income showed genuine business activity, leading to deletion of the addition.
The Tribunal held that income tax appeals cannot continue during CIRP, as the IBC moratorium bars parallel proceedings. Claims not forming part of an approved resolution plan cannot be pursued.
The Tribunal examined the validity of reopening and multiple expense disallowances. While relief was granted on cash payments and reimbursed interest, statutory interest on taxes was held to be non-deductible.
The Assessing Officer made an ALP adjustment on interest despite the assessee having already added back the full amount under thin capitalization rules. The Tribunal ruled that TP provisions cannot be applied where no expenditure is claimed.
ITAT held that penalties under sections 271D and 271E cannot survive once the underlying additions are deleted. The ruling confirms that penalties collapse with the quantum.
Alleged additions for suppressed sales, disallowances, and capital gains were rendered void once the revision order was quashed. The case underscores the doctrine of consequential invalidity.
ITAT Pune held that penalty not leviable under section 270A of the Income Tax Act since show cause notice failed to specify the applicable limb u/s. 270A(9) under which the penalty was imposed. Accordingly, penalty is quashed and appeal is allowed.
The ITAT held that assessments framed beyond the permissible ten-year block under Section 153C are without jurisdiction. Since the satisfaction note fixed the deemed search year later, earlier years were invalidly assessed.
The Tribunal ruled that absence of DIN on Section 143(2) notices vitiates jurisdiction under Section 147. All reassessment orders were quashed as legally unsustainable.
