The Tribunal held that employer-provided business advances cannot be classified as income under Section 69A without proper verification, remanding the case for limited review of TDS and expense records.
The Tribunal refused to condone a 441-day delay, ruling that failure to monitor appeal filing cannot constitute sufficient cause. The case underscores that professional lapses and lack of diligence will not excuse late appeals.
The Tribunal held that the assessee proved substantial upgrades to a semi-constructed house using bills and contractor records. It allowed the ₹4.05 crore indexed improvement cost, rejecting the AO’s suspicion-based disallowance.
The Tribunal held that the assessment was void because jurisdiction shifted between officers without a mandatory transfer order. It reaffirmed that proceedings without statutory jurisdiction are null and void.
The Tribunal held that the AO cannot expand a limited scrutiny into full scrutiny without written approval from the Principal CIT. Additions under Sections 2(22)(e) and 69A were struck down, reaffirming that CBDT instructions are mandatory.
The Tribunal held that freight amounts collected and passed on to airlines are mere reimbursements, not income. Only the assessee’s service margin is taxable.
The Tribunal found that even a belated return filed in response to a Section 148 notice remains a valid return requiring a 143(2) notice. Because this mandatory notice was never issued, the reassessment order was declared illegal and set aside.
ITAT held that the AO’s 8% estimation had no support from comparables or past margins. Applying consistency with earlier family-group cases, profit was fixed at 4% and the unexplained investment addition became academic.
The Tribunal held that ₹1.45 lakh in specified notes came from genuine vazhipadu collections and that the authorities wrongly rejected a plausible explanation.
Even though the assessee had opted for DTVSVA, the non-payment of tax meant the settlement did not materialize. The Tribunal restored the appeal to CIT(A) to examine all submitted evidence, ensuring a fair opportunity to contest additions.
