The Mumbai ITAT held that the AO and CIT(A) failed to properly verify bank statements, credit card records, and company ledger accounts before making the addition under Section 68. The matter was restored for fresh examination and reconciliation of records.
The ITAT held that old unsecured loan balances carried forward from earlier years cannot automatically be treated as unexplained cash credits in a subsequent year.
The ITAT held that reassessment notices issued on 25.07.2022 were time-barred since the Revenue had only one surviving day left under the Supreme Court’s Rajeev Bansal limitation formula.
The Chennai ITAT held that transfer pricing benchmarking cannot ignore extraordinary business circumstances arising from the shutdown of a major customer. The Tribunal upheld deletion of TP adjustment after accepting that sale of goods to the AE was a distress sale triggered by Nokia India’s closure.
The ITAT held that mere disclosure of undisclosed income during search is insufficient for immunity under Section 271AAA unless the assessee substantiates the manner in which such income was derived.
The ITAT held that CSR expenditure disallowed as business expenditure under Section 37(1) can still qualify for deduction under Section 80G if statutory conditions are satisfied. Revision under Section 263 was accordingly quashed.
The ITAT held that unverified third-party excel sheets without corroborative evidence cannot justify additions under Sections 69 or 69A. The Tribunal observed that mere electronic entries amount to dumb documents unless independently verified.
The ITAT ruled that accepted sales necessarily imply corresponding purchases, even if sourced through the grey market. The addition was therefore restricted to estimated profit instead of the full purchase amount.
The Tribunal held that the AO wrongly aggregated actual property value and stamp duty valuation of the same transaction to invoke extended limitation under Section 149(1)(b). The reassessment notice for AY 2015-16 was declared time-barred and without jurisdiction.
The Mumbai ITAT held that no separate addition for alleged bogus purchases can be made where the assessee has already disclosed a higher gross profit on disputed transactions. The Tribunal relied on Bombay High Court rulings limiting additions only to differential GP.
