The issue was whether reassessment beyond 3 years is valid when escaped income is below ₹50 lakh. The ruling held such notice invalid under Section 149, and the key takeaway is strict adherence to limitation rules.
The Tribunal examined whether cash deposits backed by prior withdrawals can be taxed as unexplained income. It ruled that in absence of evidence showing alternative use of cash, the source stands explained.
The Tribunal examined whether demonetisation cash deposits linked to recorded business sales could be taxed as unexplained income. It ruled that once the source is established through books, addition under Section 68 is unsustainable.
The Tribunal ruled that failure to specify underreporting or misreporting in notice invalidates penalty. Proper identification of charge is mandatory for valid proceedings.
ITAT held that reassessment initiated with approval from the wrong authority is invalid when issued beyond three years. The entire proceedings were quashed. The key takeaway is that proper sanction under Section 151 is mandatory.
ITAT held that estimating profit at 8% without considering records was excessive. It reduced the rate to 3% based on business realities. The key takeaway is that estimation must be reasonable and evidence-based.
ITAT rejected condonation of a 963-day delay as the assessee failed to provide supporting evidence for the reasons stated. The Tribunal held that mere claims without proof cannot justify delay.
The Tribunal condoned a delay of 615 days after finding that the assessee was actively pursuing rectification remedies under Section 154. It held that such bona fide conduct constitutes sufficient cause and delay cannot be treated as negligence.
ITAT held that an unexplained delay of over 11 years cannot be condoned without valid reasons. The appeal was dismissed as no sufficient cause was proved.
ITAT held that late filing of Form 67 is only a procedural lapse and not a ground to deny FTC. The matter was remanded for verification and grant of eligible credit.
