The ITAT held that Rule 8D cannot be invoked without first recording a clear dissatisfaction with the assessee’s working based on accounts. Mechanical application of the rule, without identifying specific expenditure linked to exempt income, was ruled invalid.
The ITAT held that filing Form 10B on the extended due date, especially during COVID-19 relief periods, cannot by itself defeat Section 11 exemption. Procedural delay cannot override substantive compliance.
Chennai ITAT held that dismissing appeals as non-maintainable was erroneous. Orders giving effect to appellate directions retain their character as assessment orders.
The question was whether the extended ten-year window under Section 153C could be invoked. The Tribunal held that where the satisfaction note shows escaped income below ₹50 lakh, the extended limitation is unavailable.
The ITAT noted that cash-flow statements showing withdrawal–redeposit nexus were not examined. Non-consideration of material evidence warranted remand.
The ITAT held that a notice under Section 143(2) issued by a non-jurisdictional officer is invalid. Such a defect strikes at the root of the assessment and cannot be cured.
The ITAT held that capital gains under Section 50C cannot be mechanically applied where a sale deed is alleged to be an erroneous document and no real transfer occurred. The case was remanded to verify whether the transaction was actually a gift with no consideration or possession transfer.
The case involved reassessment based on alleged cash payment for property. The Tribunal held that basic fact-checking is mandatory before confirming a ₹71.23 lakh addition under Section 69A.
ITAT Mumbai held that additions made on substantive and protective basis merely on the strength of BUP IDs, internal identifiers, and presumptive opening deposits are unsustainable. Accordingly, appeal of revenue dismissed.
The ITAT held that documented share transactions through recognised exchanges cannot be treated as bogus without contrary proof. General investigation reports and suspicion were held insufficient to sustain additions.
