ITAT Jaipur held that addition made on the basis of documents found from the third party without providing any opportunity of cross-examination is liable to be deleted on the ground of violation of principles of natural justice.
The Tribunal held that the appellate authority failed to pass a reasoned order under Section 250(6) and remanded the case for fresh consideration, directing that proper opportunity be given to the assessee.
The Tribunal held that reassessment proceedings initiated without a properly signed Section 151 approval are invalid. The notice under Section 148 was quashed, and the assessee’s appeal was allowed.
The Tribunal allowed Section 80P deduction on bank interest after finding no binding jurisdictional ruling and applying the principle that the favorable view must prevail. The key takeaway is that surplus deposit interest qualifies for deduction in such circumstances.
Tribunal deleted protective additions after finding no corresponding substantive assessment. The ruling clarifies that protective action cannot stand alone under Sections 147/143(3).
Tribunal upheld disallowance of Section 54F exemption after the assessee failed to prove ownership of the residential property. The ruling confirms that deduction requires clear evidence of title.
ITAT examined Revenue’s protective addition based on alleged beneficial ownership of foreign accounts. It upheld deletion after noting unresolved ownership and procedural gaps, emphasizing that protective additions require clear foundational evidence.
Tribunal allowed Section 80P deduction for interest on surplus bank deposits, emphasizing that in absence of binding jurisdictional guidance, the assessee-favorable view applies.
ITAT Chandigarh ruled that cash gifts from close relatives, supported by affidavits and audited accounts, cannot be treated as unexplained income. The assessee’s appeal was allowed.
The ITAT confirmed an addition of Rs. 28 lakh under Section 69A, ruling that the assessee failed to substantiate the source of cash deposits made over four years. Burden of proof lies on the taxpayer to explain deposits.
