The Tribunal ruled that a Section 148 notice issued after six years from AY 2013–14 was invalid, quashing the reassessment and additions under Section 54F.
Tribunal accepted the assessee’s explanation for delay and held that denial of opportunity justified remand for fresh assessment under Section 147/144B.
Tribunal found that the CIT(A) admitted new evidence without AO’s opportunity and remanded the case for re-examination of NRE deposit sources under Section 69.
Tribunal held that a minor delay should not defeat justice and directed CIT(A) to hear the case on merits, citing violation of Section 250(6).
Tribunal held that deduction under Section 54 depends on amount actually invested in a new property and not on ownership proportion. Assessing Officer’s restriction to 50% due to joint ownership was set aside, confirming relief for assessee.
The Tribunal accepted medical reasons for delay, found notice service defective, and set aside a non-speaking CIT(A) order for fresh adjudication under Section 250(6).
Tribunal ruled that disallowance for not filing Form 10 can only apply in the year of default, not later years of utilization. Addition of ₹80 lakh deleted.
The Tribunal held that CIT(A) must decide all grounds, including legality of reopening under Section 147/148. Order remanded for fresh adjudication under Section 250(6).
ITAT ruled that ₹10 lakh deposit in demonetisation period, backed by gifts, savings, and sale of gold, cannot be treated as unexplained under section 69A.
The appellate authority held that additions cannot be sustained solely on external information without independent verification. Bogus purchase claims under Section 69A were deleted.
