The Tribunal held that interest earned by a co-operative society from investments with co-operative banks falls within Section 80P(2)(d). Such income is deductible, subject to verification of the source and bifurcation.
Cash deposits followed by regular transfers to the telecom operator established a clear business cycle. The ruling confirms that explained business receipts cannot be treated as unexplained cash.
The ITAT held that an assessment made in the name of an amalgamated company is void ab initio, even where proceedings continued after merger intimation.
The Tribunal held that a Section 148A(d) order passed by a jurisdictional AO after the faceless notification is without legal authority. Any reassessment founded on such an order is void for want of jurisdiction.
The Tribunal ruled that post-notification reassessment notices must strictly follow the faceless assessment framework. Issuance by a jurisdictional AO renders the notice without authority and the reassessment unsustainable.
The Tribunal held that where reassessment is based solely on search material found during a third-party search, proceedings must be initiated under section 153C. Reopening under section 147 was held to be without jurisdiction and quashed.
The Tribunal held that corpus donations cannot be denied merely due to technical lapses like student collection or minor PAN errors. Donor intent and consistent treatment in books were sufficient to allow exemption under section 11(1)(d).
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.
