The Tribunal found that hearing notices were sent to the wrong email address, resulting in an ex-parte order. The matter was remanded to the AO after directing the assessee to deposit ₹5,000 as costs.
The AO alleged concocted sales but brought no evidence, and the CIT(A) also found no discrepancies in the accounts. With complete documentation showing genuine sales and business use of funds, the Tribunal removed most of the addition. Section 115BBE was also ruled inapplicable for the year.
ITAT Delhi held that PCIT’s revision under section 263 on alleged bogus sales was invalid since the same transactions were already under appeal before CIT(A). Substituting the AO’s judgment without showing assessment was erroneous and prejudicial was impermissible.
ITAT Delhi admitted additional evidence proving that bank credits considered unexplained were interest income already declared in returns. The Revenue could not contest the factual reconciliation. The penalty under section 271(1)(c) was deleted in full.
ITAT Delhi deletes ₹16.97 Cr addition; Denmark-based LM Wind Power AS has no PE or business connection in India. Royalty taxable u/s 115A; penalty u/s 271AA unsustainable.
ITAT Delhi deletes ₹2.10 Cr addition u/s 68 for share call-money; statements not supplied or cross-examined. Identity, creditworthiness & genuineness of subscribers proven; ad-hoc disallowance also deleted.
The Tribunal examined alleged bogus payments to 27 sub-contractors treated as undisclosed income. While the Assessing Officer made large additions, the assessee provided affidavits confirming genuineness. The ruling partly allowed the appeals, stressing careful verification of evidence rather than assumptions.
ITAT Chennai struck down a protective addition of ₹14.91 Cr made u/s 69, citing invalid u/s 153C jurisdiction. No substantive assessment existed in the companies’ hands for AY 2014-15, reinforcing that protective additions require year-wise satisfaction and corroborative evidence.
Tribunal confirmed that powers to question “source of source” under section 68 exist only from 01-04-2023. Additions on unsecured loans and student deposits were deleted, while TDS disallowance was remanded.
ITAT Chennai ruled that for captive power consumption, the market value for Section 80-IA deduction should be the rate at which electricity is supplied to industrial consumers, not the SEB purchase rate. AO’s downward adjustment was deleted.
