The Tribunal held that the assessees misunderstanding about the relevance of quantum proceedings justified remanding the 271B penalty order. The AO is directed to consider the assessees factual explanations without unnecessary adjournments.
ITAT Chennai quashed reassessment under Section 147, ruling that reopening based on a change of opinion without new material is invalid.
The Hyderabad tribunal clarified that section 144C provisions are procedural and cannot extend the statutory limitation under section 153. The AO passed the final assessment order after the permissible period, leading to quashing. The ruling strengthens the principle that statutory deadlines are paramount in tax proceedings.
The Tribunal upheld the rejection of unreliable books but ruled that the AO could not estimate net profit at 12% without justification, vacating ₹65.08 lakh addition.
ITAT restored Rs. 20 Cr in unsecured loans, interest, and squared-up loans for fresh verification, noting CIT(A) erred by deleting additions at the stroke of a pen. Large new loans and substantial repayments required independent checks on purpose and creditworthiness. The ruling reinforces that appellate deletion without inquiry violates Rule 46A and legal principles under sections 68 and 69.
Rs. 99.86 Cr out of Rs. 110 Cr added as current liabilities was deleted by CIT(A) and upheld by ITAT. Verification of ledgers, statutory dues, and party confirmations showed actual liability reduction during the year. This highlights the role of detailed evidence in defending balance sheet claims.
The issue involved a common sanction letter covering multiple assessees and years, issued on the same day the AO sought approval. ITAT found this composite approval inconsistent with judicial mandates requiring individualized scrutiny. As a result, the assessment was declared void ab initio, making all additions infructuous.
The Tribunal held that the appeal should be heard on merits after the CIT(A) dismissed it solely for a 45-day delay. It restored the matter for fresh adjudication, directing that the delay issue not be reconsidered.
The Tribunal remanded the sustained cash deposit addition after accepting additional evidence. It directed the CIT(A) to reconsider the ₹7.02 lakh addition through de novo adjudication.
The Tribunal held that the AO’s rejection of books under Section 145(3) was unsustainable as no specific defects were identified. The ruling confirms that estimation of income cannot be based on assumptions when records are supported by documentation.
