The Tribunal held that reassessment under section 147 fails when the alleged income escapement cited for reopening is accepted and no related addition is made. Without sustaining the original reason for reopening, jurisdiction itself collapses.
The Tribunal upheld the remand of an ex parte assessment where substantial bank deposits were not supported by any documentary evidence. It held that unsupported explanations cannot replace proof, and fresh verification by the Assessing Officer was necessary.
The Tribunal held that section 50C could not be applied where the sale consideration exceeded the value accepted by the stamp authority. A clerical error in departmental data could not justify substitution of sale value.
The Tribunal held that denial of TDS credit solely on mismatch grounds requires factual verification. The Assessing Officer must examine whether the individuals in whose names TDS was deducted have already claimed the credit.
The tribunal held that assessments selected for limited scrutiny cannot include additions on unrelated issues without formal conversion to complete scrutiny. All such additions were set aside as being without jurisdiction.
The case examined the tax treatment of purchases from alleged accommodation entry providers. The Tribunal held that at best, only the profit element embedded in such purchases can be brought to tax.
The Assessing Officer disallowed interest expenditure in an ex parte order under section 144. The Tribunal ruled that once evidence shows a clear link between interest paid and interest earned, the deduction must be allowed.
The application was rejected only on limitation without examining merits. The Tribunal ruled that bona fide delay must be condoned and eligibility under section 80G(5) examined afresh.
ITAT Delhi held that Final Assessment Order passed u/s 143(3) r.w.s. 144C(13) passed beyond time limit prescribed under section 153 of the Income Tax Act is barred by limitation. Accordingly, Final Assessment Order is liable to be quashed.
The Revenue relied on ITS data to allege unexplained cash deposits. The Tribunal ruled that where cash books and stock registers are maintained without defects, such additions are unsustainable.
