The Tribunal found that once additions under Sections 68 and 69C were deleted, penalty became infructuous. The ruling highlights the dependency of penalty on assessment findings.
ITAT held that absence of an irrevocability clause cannot justify rejection of 80G approval. The case was remanded to CIT(E) to reconsider in line with binding High Court ruling.
ITAT allowed additional evidence filed by the legal heir and remanded the matter to the AO for verification. The key takeaway is that justice requires giving opportunity where evidence was earlier unavailable.
The Tribunal noted that the assessee provided affidavits, bank statements, and financials of contributors. The addition was deleted as the source stood satisfactorily explained.
The tribunal ruled that failure to strike off irrelevant portions in penalty notice makes it legally defective. Such ambiguity invalidates the entire penalty levy.
The Tribunal held that audited accounts cannot replace documentary evidence for claiming application of income. The case was remanded for fresh verification.
The Tribunal found that the AO relied only on general information without corroborative material. The ruling emphasizes that suspicion cannot replace proof in tax proceedings.
The tribunal ruled that revisionary powers cannot be exercised without questioning the statutory approval under Section 153D. Absence of such examination renders Section 263 action invalid.
The notice issued after the permissible window calculated under TOLA and judicial rulings was held void. The case highlights strict adherence to limitation timelines.
The Tribunal ruled that supplying only a summary of reasons is insufficient in law. The failure to furnish recorded reasons vitiated the entire reassessment.
