The case addressed whether recorded purchases of ₹4.55 crore could still be treated as unexplained income. The Tribunal held that without evidence of off-book investments, section 69 has no application.
The Tribunal ruled that payments for IPL and MPLS bandwidth services do not constitute royalty under section 9(1)(vi) or Article 12(3) of the India-Singapore Tax Treaty, following consistent earlier rulings.
The Tribunal ruled that non-filing of submissions alone cannot justify confirming penalties under section 271D. CIT(A) orders were set aside, and reassessment was directed after providing full hearing rights.
ITAT Chennai confirmed that 8% profit estimation for a civil contractor was reasonable, rejecting the assessee’s 6% claim and AO’s 10% estimate, emphasizing consistency with subsequent years’ presumptive returns.
ITAT Delhi held that Section 153C proceedings cannot proceed on mere suspicion; the AO must establish that seized material impacts the assessee’s total income. The assessments for AYs 2018-19 and 2019-20 were fully quashed.
Tribunal held that non-filing of submissions or non-appearance cannot override substantive justice. CIT(A)’s order confirming additions was set aside, and matter remitted for fresh hearing.
ITAT Mumbai ruled that a co-operative society’s deposits in co-operative banks are eligible for deduction under section 80P(2)(d), despite section 80P(4) limiting banks themselves. The decision reinforces liberal interpretation of 80P to support the co-operative sector.
The Tribunal ruled that interest from deposits with co-operative banks qualifies for deduction under section 80P(2)(d). The is that co-operative banks still meet the legal definition of a co-operative society.
The Tribunal held that past cash withdrawals cannot justify demonetisation deposits without evidence of continued cash holding. The is that unexplained deposits attract section 69A.
The ITAT Delhi invalidated assessments where the AO failed to record year-wise satisfaction linking seized material to the assessee. Proper satisfaction is essential for initiating Section 153C proceedings.
