ITAT Mumbai deleted Sec 69 addition for alleged on-money, holding third-party statements and pen-drive data without cross-examination or corroboration are invalid evidence.
The Tribunal clarified that dismissal of an SLP does not amount to declaration of law under Article 141. It distinguished prior rulings and held that defective penalty notices invalidate the levy.
ITAT Mumbai held stamp duty value on allotment date applies u/s 56(2)(x) where full payment was made by cheque before agreement, not registration date value; matter remanded for verification.
The Tribunal emphasized 33%–40% value addition at the UTK unit and scientific assembly processes to conclude that real manufacturing took place. It directed deletion of disallowances made across five assessment years.
The ITAT Bangalore held that penalty under Section 270A for alleged underreporting and misreporting of income could not survive once the Karnataka High Court condoned the delay in filing the return and restored the assessee’s eligibility for deduction under Section 80IA.
The ITAT Bangalore held that the entire cost of construction claimed by the assessee while computing capital gains on sale of property could not be outrightly disallowed merely due to lack of complete supporting documents.
The ITAT Bangalore held that reopening of assessment was invalid as it was based on an incorrect assumption that the assessee had claimed bogus long-term capital gains (LTCG) from penny stock transactions.
ITAT Bangalore quashed Sec.263 revision, holding AO had examined Model House and ₹9.68 cr expenses in detail; mere change of opinion cannot justify revision.
The Tribunal held that the reassessment notice issued after the extended limitation period was invalid under Section 149. As a result, the entire reassessment based on alleged accommodation entries was quashed as void ab initio.
ITAT Bangalore quashed reassessment for AY 2017-18, holding notice issued on 12-04-2024 time-barred under first proviso to Sec.149(1), despite prior 148A proceedings.
