ITAT Bangalore held that Section 154 cannot be invoked to make a fresh disallowance of an asset write-off claim that was never examined in the original assessment. The Tribunal ruled that such an issue is not a mistake apparent from the record and falls outside the scope of rectification.
ITAT Bangalore held that the Income-tax Act does not prohibit a charitable trust from filing a second application for registration under Section 12AB after an earlier rejection.
ITAT ruled that the reassessment order passed under Section 147 was unsustainable as it exceeded the limitation period prescribed by the Income-tax Act. The decision highlights that statutory timelines cannot be ignored without supporting evidence from the Revenue.
ITAT Bangalore deleted the penalty under Section 270A after holding that the assessee’s incorrect claim arose from a bona fide misunderstanding of a newly introduced provision under Section 71(3A).
ITAT Bangalore held that reassessment cannot survive where the Assessing Officer makes no addition on the very issue for which the assessment was reopened. The Tribunal deleted the Section 54 disallowance, holding that additions on unrelated issues are unsustainable once the original reopening ground fails.
ITAT Bangalore held that a ₹5 lakh investment could not be treated as unexplained under Section 69 where documentary evidence showed it was made through a cheque issued by the tenant under a lease arrangement.
ITAT Bangalore held that a genuine claim of application of income supported by documentary evidence cannot be denied merely because of a reporting mismatch in different schedules of the income tax return.
ITAT Bangalore held that where the assessee disputed the stamp duty valuation and furnished a registered valuer’s report, the Assessing Officer ought to have referred the matter to the Departmental Valuation Officer (DVO).
ITAT Bangalore held that once a search under Section 132 was conducted, the assessment for the relevant year had to proceed under Section 147/148 in accordance with the post-2021 statutory scheme.
The ITAT Bangalore held that a mismatch between the income tax return and Form 3CD cannot by itself justify disallowance of a genuine bonus payment. It allowed the deduction after finding that the payment was supported by books of account and bank records.
