The AO treated loans as unexplained due to incomplete confirmations. The Tribunal confirmed deletion after remand proceedings verified lenders’ identity, capacity, and transaction genuineness.
The reassessment was struck down because it relied exclusively on third-party search material. The ruling clarifies that section 153C, not section 147, must be invoked where incriminating evidence emerges from another persons search.
A Section 57(iii) interest claim was rejected solely due to the loan’s classification as a home loan. The tribunal held that if allowed earlier, the same view must prevail unless facts change.
The AO had treated all bank cash deposits as unexplained under section 69A. The Tribunal held that regular cash sales explained most deposits and restricted the addition to ₹10 lakh only.
The Tribunal held that a protective addition cannot be termed erroneous when the same income has already been assessed substantively in another case. The twin conditions of error and prejudice under section 263 were not satisfied.
The Tribunal ruled that when all statutory documents are on record and unchallenged, section 68 cannot be invoked. Suspicion cannot substitute proof in share capital cases.
The issue was whether reassessment could be initiated for an amount implicitly accepted in original assessment. The Tribunal ruled that reopening amounted to change of opinion and was legally unsustainable.
ITAT Delhi held that cash deposits during demonetisation were fully explained by cash sales recorded in regular books. When books are not rejected and sales are accepted, separate addition is unsustainable.
The Tribunal ruled that section 234E fee cannot be imposed for periods before 01.06.2015. In absence of jurisdictional High Court ruling, the interpretation favourable to the assessee was adopted.
The dispute included disallowance under section 14A exceeding exempt income. The Tribunal upheld restriction of disallowance to the amount of exempt income and rejected a higher computation. The decision reinforces judicial limits on Rule 8D application.
