ITAT Raipur quashes Sec 147 reassessment in ITO Vs Bishambhar Dayal Agrawal. Held reopening based on change of opinion, not new material, is invalid. Cites Kelvinator.
ITAT Pune held that satisfaction note is required to be recorded u/s.153C for each assessment year, thus, recording of consolidated satisfaction note for different assessment years (AY) would vitiate the entire assessment proceedings.
ITAT Jaipur held that addition towards undisclosed income rightly sustained since assessee failed to explain the incriminating material found during the course of search. Penalty under section 271AAB too sustained.
ITAT Raipur held that application for registration u/s. 12A(1)(ac)(iii) of the Income Tax Act rightly rejected since assessee, without any justifiable reason, failed to provide requisite details/ documents specifically called by CIT(E).
ITAT Delhi held that CIT(E) has rejected application for registration u/s. 80G(5)(iii) of the Income Tax Act without giving cogent reason by disposing the matter in hyper technical manner without discussing on merits is not tenable in law.
ITAT Raipur held that penalty u/s. 271(1)(c) of the Income Tax Act is liable to be struck down for the failure on the part of the A.O. to put the assessee to notice as regards the default for which penalty under Sec. 271(1)(c) was sought to be imposed.
ITAT Mumbai held that disallowance of interest expenditure attributable to interest-free advances not justified since sufficient interest free funds available and also there existed commercial expediency in giving interest free advances. Accordingly, appeal of revenue dismissed.
ITAT Bangalore deletes additions under Section 69 citing presumptive taxation under Section 44AD and lack of supporting evidence by the AO.
ITAT Chandigarh deleted additions made by AO for alleged undisclosed land investment based on uncorroborated mobile images in Harvinder Kaur case.
ITAT Surat rules penalty under Section 271(1)(c) not sustainable where income addition is based on estimation of bogus purchases.
