Delhi ITAT held that reassessment beyond four years is invalid if the Assessing Officer fails to record how the assessee failed to fully and truly disclose material facts. The Tribunal quashed the reopening for violating the first proviso to Section 147.
ITAT Ahmedabad held that depreciation on goodwill arising from amalgamation was allowable for assessment years prior to AY 2021-22. The Tribunal ruled that amendments excluding goodwill from depreciable assets operate prospectively.
Delhi ITAT held that revision under Section 263 cannot be invoked merely because the PCIT desires deeper investigation after detailed assessment scrutiny. The Tribunal found that the AO had examined all major issues through extensive enquiries and documentation.
The Tribunal ruled that the Assessing Officer wrongly invoked Section 143(3) despite the case being covered under the block assessment provisions of Section 153C. ITAT reaffirmed that jurisdictional defects cannot be cured by regular scrutiny proceedings.
Delhi ITAT held that investments in immovable properties cannot be treated as unexplained once payments are made through disclosed bank accounts with explained credits. The Tribunal deleted ₹3.29 crore addition for lack of incriminating material.
Delhi ITAT held that cancellation of GST registration and non-response from suppliers alone cannot justify treating entire purchases as bogus. The Tribunal restricted the addition to 5% profit element, observing that sales and books of account were not rejected.
The Delhi ITAT held that large cash deposits and investigation wing information alone do not create valid reason to believe for reopening assessment under Section 147. The Tribunal ruled that reassessment based on suspicion and borrowed satisfaction is invalid in law.
The Kolkata ITAT held that penalty under Section 271(1)(c) cannot be levied where income addition is based on peak credit estimation. The Tribunal ruled that estimated additions do not automatically prove concealment or inaccurate particulars.
The ITAT upheld disallowance of ₹11.71 lakh towards loan processing fees after finding that the loans were obtained for broader business purposes and not for acquiring the property generating rental income. The ruling clarified the limited scope of deductions available under Section 24(b).
ITAT Mumbai held that stamp duty valuation on the date of allotment should be considered where property consideration was fixed earlier and payments were made through banking channels before registration.
