The Tribunal examined the validity of assessments initiated under Section 153C where the Assessing Officer recorded a single consolidated satisfaction note for multiple assessment years. Following binding precedents, the Tribunal held that consolidated satisfaction is a fatal jurisdictional error and quashed the 153C assessments entirely.
The Tribunal noted that the cash was seized in a case involving narcotics, making the assessees story of property-related pooling of funds implausible. With no credible corroboration and significant inconsistencies, the addition under section 69A was upheld. The ruling stresses that factual context can outweigh self-serving explanations.
Assessing the full cash component of a property sale in the hands of one legal heir was found to be factually incorrect, leading the Tribunal to delete the addition. The appellate authority confirmed that the proceeds were jointly receivable by all co-owners and could not be attributed to the Assessee exclusively as unexplained credit.
Tribunal remands the matter after finding that bank records showing cash withdrawals were not examined. The key takeaway is that cash-in-hand cant be treated as unexplained without proper factual verification.
ITAT condones delay in filing appeal as the assessee’s police duties prevented timely submission, restoring the matter for adjudication on merits.
ITAT Mumbai ruled that non-resident investments sourced from foreign salary cannot be treated as unexplained income, deleting ₹2 crore addition under Section 69.
The ITAT Delhi upheld the allowance of management fees after verifying proper documentation and business purpose, emphasizing that payments to a parent company are deductible if fully supported.
The ITAT Delhi invalidated the reopening of an income tax assessment because the assessee had filed a complete return and the AO failed to record valid reasons, highlighting the need for proper statutory compliance in reassessment.
The ITAT remanded a case where a charitable society’s 80G(5) registration was rejected because incidental sales were misclassified as business income. The Tribunal emphasized evaluating the society’s charitable purpose and proper documentation.
The ITAT Delhi partly allowed the appeal as the AO/TPO selected a company that failed the turnover filter for transfer pricing. Key takeaway: Transfer pricing adjustments must follow proper comparability filters and FAR analysis.
