ITAT examined Revenue’s protective addition based on alleged beneficial ownership of foreign accounts. It upheld deletion after noting unresolved ownership and procedural gaps, emphasizing that protective additions require clear foundational evidence.
Tribunal allowed Section 80P deduction for interest on surplus bank deposits, emphasizing that in absence of binding jurisdictional guidance, the assessee-favorable view applies.
ITAT Chandigarh ruled that cash gifts from close relatives, supported by affidavits and audited accounts, cannot be treated as unexplained income. The assessee’s appeal was allowed.
The ITAT confirmed an addition of Rs. 28 lakh under Section 69A, ruling that the assessee failed to substantiate the source of cash deposits made over four years. Burden of proof lies on the taxpayer to explain deposits.
ITAT dismissed appeals and upheld 271B penalties as the assessee failed to audit accounts despite turnover exceeding Rs. 1 crore. No reasonable cause was shown.
ITAT restricted unexplained cash addition from Rs.78 lakhs to Rs.7 lakhs, granting relief on demonetization deposits while maintaining that it is not a precedent-setting decision.
The Tribunal ruled that once the assessee responds to a 148A(b) notice, the AO must complete the 148A(d)–148 cycle within the remaining time. In this case, the notice overshot the surviving limitation period, making reassessment legally defective. Consequently, all additions related to alleged accommodation entries and loans were quashed.
ITAT Delhi held that assessments under section 153C are invalid if the AO of the searched person fails to record a mandatory satisfaction note, emphasizing jurisdictional compliance.
Tribunal quashed reopening under Section 147 where AO’s presumption of non-filing contradicted the documented return, citing Deepak Wadhwa precedent.
The decision highlights that additions under Section 153C cannot stand when based only on third-party statements without seized material linking the assessee. The ruling stresses the need for concrete evidence before treating purchases as non-genuine.
