The Tribunal held that a genuine and reasonable explanation for delay justified condonation of nearly three years. It emphasized that substantial justice should prevail over technical limitations when no mala fide intent is established.
The assessee sought deduction for property tax paid during the relevant financial year but failed to claim it in the return. The ITAT granted another opportunity and ordered verification of the claim on merits.
ITAT held that the assessee discharged the primary burden under Section 68 by producing complete documentary evidence regarding the lender and the loan transaction. The addition was deleted because the Revenue failed to disprove the evidence.
The assessee contended that cash deposits in the bank account represented sales proceeds from a medicine business. The ITAT remanded the matter to the Assessing Officer to verify turnover details and determine taxable income on a reasonable basis.
The Pune ITAT held that estimating net profit at 18% of contract receipts was excessive in the absence of supporting material. Applying principles similar to presumptive taxation under Section 44AD, the Tribunal restricted the profit rate to 8% and granted substantial relief.
The ITAT held that Section 40(a)(ia) could not be invoked where the assessee had not made the rent payments referred to in the tax audit report. The addition was traced to an inadvertent reporting error by the auditor.
The Tribunal ruled that a notice issued beyond three years from the relevant assessment year requires sanction from the authority prescribed under Section 151. Since approval was obtained from the wrong authority, the reassessment proceedings were held to be illegal.
The Tribunal held that the reassessment order was invalid because it was passed within four weeks of disposing of the assessee’s objections to reopening. Following Bombay High Court precedents, the reassessment proceedings were quashed.
The Tribunal found that the assessees claim for deductions under Chapter VI-A required factual verification rather than outright rejection. It directed the Assessing Officer to reconsider the claim after examining relevant documents and evidence.
ITAT held that a typographical mistake in selecting the wrong sub-clause of Section 80P does not defeat a valid deduction claim. The Tribunal directed the Revenue to grant the full deduction where eligibility was otherwise undisputed.
