Additions under section 153A were deleted as they rested only on an unowned diary without proof of authorship or corroborative evidence. The ruling reinforces that suspicion cannot substitute proof in search cases.
The case examined a large disallowance under section 40A(2)(b) for purchases from a group concern. The Tribunal ruled that without market comparables or proof of inflated pricing, related-party payments cannot be treated as excessive.
The trust sought exemption by invoking later registration under section 12AA. The tribunal ruled that exemption cannot be granted retrospectively through section 154 when no assessment was pending on the registration date.
Revenue issued 153C notices for years far preceding the satisfaction date. Following binding judicial precedent, the tribunal ruled that such assessments were beyond the ten-year statutory window and could not survive.
The core question was whether DDA could be treated as a non-exempt payee for TDS purposes. The tribunal reaffirmed that DDA is a local authority, making section 194I inapplicable to ground rent payments.
Delhi ITAT ruled that purchases from paper companies cannot be treated as normal business expenses under Section 37(1). Fraudulent transactions with no goods delivered attract unexplained expenditure taxation under Section 69C and 115BBE.
The appellate authority had mechanically rejected additional evidence without reasons, resulting in denial of fair opportunity. The tribunal restored the quantum issue for reconsideration and quashed the consequential penalty.
The Tribunal held that revision cannot be based on alleged lack of enquiry when detailed verification was already done. A mere change of opinion does not justify section 263 action.
Applying the timelines prescribed in Rajeev Bansal, the Tribunal found the notice issued after the permissible window. The ruling reinforces strict adherence to limitation in reassessment cases.
The Tribunal held that a notice dated 31.03.2021 but dispatched after 01.04.2021 is governed by the new reassessment regime. Failure to follow section 148A procedures rendered the entire reassessment void.
