The Tribunal ruled that audited books and quantitative reconciliation supported the genuineness of agricultural commodity purchases. In the absence of contrary evidence, arbitrary disallowance of purchases could not be sustained.
The Delhi ITAT held that additions made on transactions unrelated to the reasons recorded for reopening were beyond the Assessing Officer’s jurisdiction. The reassessment addition was therefore deleted.
The ITAT Chandigarh held that once registration under Section 12AB had been directed to be granted, the primary basis for rejecting approval under Section 80G ceased to exist. The matter was remanded to examine the remaining statutory conditions under Section 80G.
The Delhi ITAT found that the Assessing Officer lacked legal authority to reopen assessment years lying outside the ten-year block period computed under Section 153C. Revenue’s appeals challenging the CIT(A)’s decision were dismissed.
ITAT Chennai restored the matter to the Assessing Officer after finding that the assessment and appellate proceedings were concluded ex parte without deciding the issues on merits. The Tribunal granted the assessee one final opportunity to substantiate the source of cash deposits with evidence.
ITAT Kolkata upheld the deletion of disallowance relating to brought forward losses of an amalgamating company after finding that the amalgamated entity had continued the business and retained the prescribed fixed assets. The Tribunal held that there was no evidence showing non-compliance with Section 72A(2).
The Bangalore ITAT held that ambiguity in the penalty proceedings rendered the levy unsustainable. The Tribunal emphasized strict compliance with the statutory framework under Section 270A.
The ITAT condoned the delay after finding that assessment and appellate notices were sent to incorrect email addresses. The ruling highlights the importance of valid service of notices in tax proceedings.
The ITAT observed that invoking the test of human probabilities cannot replace factual verification of books and bank records. Additions under Section 69A require evidence showing that the disclosed cash was unavailable.
The ITAT found that provisions for identified legal and professional expenses represented crystallized liabilities requiring TDS deduction. The key takeaway is that only genuine contingent liabilities may escape such obligations.
