Demat and broker records showed actual purchases of Rs. 1.24 crore and sales of Rs. 85 lakh, contradicting the AO’s addition of Rs. 2.11 crore. The Tribunal remitted the matter for detailed examination. Proper transaction-wise verification is essential before treating share activity as unexplained income.
The Tribunal upheld deletion of a Rs. 17.93 crore disallowance since the assessee earned no exempt income during the year. It applied binding High Court rulings holding that Section 14A cannot operate without exempt income. The decision confirms that the 2022 amendment to Section 14A is prospective.
The Tribunal held that reassessment after four years requires PCIT approval, not Additional CIT. The invalid sanction led to quashing of the Section 148 notice and dismissal of Revenue’s appeal.
ITAT held that cash deposits made during demonetization without proof of source justified addition under Section 69A. The ruling reinforces that dissolved entities must substantiate cash claims with evidence.
The Tribunal held that suspicion or reference to unconnected investigations cannot justify denying legitimate interest expenditure. It reiterated that opening balances accepted in earlier years cannot be treated as non-genuine in a subsequent year without contrary evidence.
The ITAT held that an assessee’s procedural lapses cannot override statutory entitlement to deductions under section 10A. The AO must verify substantive conditions, including STPI registration and export realization, before rejecting a claim.
The ITAT held that reassessment notices issued without the correct statutory sanction under section 151(ii) are void ab initio, emphasizing that procedural compliance is crucial before examining merits of the case.
ITAT Delhi held that the LTCG derived from exclusive transfer of equity shares and units of equity oriented mutual funds only is held eligible for exemption under section 10(38) of the Income Tax Act. Thus, ground raised by the revenue stands allowed.
ITAT Chandigarh ruled that income and valuation additions based solely on third-party digital data or statements cannot be made without corroboration from the assessee’s records, leading to deletion of disputed amounts.
Mukesh Arvindlal Vakharia Vs ITO (ITAT Surat) ITAT Allows Full 54EC Relief Because Investments Were in Two Financial Years; 54EC Deduction Restored as Advance Money Investment Considered Valid; 54F Claim Denied Because Joint Ownership Counts as Second House; Section 54F Exemption Refused Due to Ownership of Multiple Residences; Expense Deduction Rejected Since Firm Interest Cannot […]
