The tribunal held reopening invalid where actual escaped income was below ₹50 lakh. It clarified that jurisdiction depends on real income, not transaction value.
The Tribunal ruled that revision under Section 263 requires examination of approval granted under Section 153D. Without establishing any defect in such approval, the assessment cannot be termed erroneous. The decision limits arbitrary revision powers.
The Tribunal held that additions cannot be sustained merely on third-party Excel sheets and statements. It ruled that absence of independent evidence and denial of cross-examination renders such additions invalid.
The Tribunal ruled that incorrect invocation of Section 69A does not invalidate the addition. Since the loan was found to be an accommodation entry, it was sustained under Section 68. The decision emphasizes substance over technical defects.
ITAT held that the assessee discharged the burden of proving identity, creditworthiness, and genuineness. Addition was deleted as AO relied only on suspicion without evidence.
ITAT remanded the matter where the assessee claimed PAN misuse leading to additions under Sections 68 and 69. It directed AO to verify the police report, holding that relief must be granted if misuse is substantiated.
The Tribunal held that delay in filing Form 67 is a procedural lapse. It restored the matter to the AO to verify and allow Foreign Tax Credit if eligible.
The Tribunal held reassessment invalid as no proper sanction under Section 151 was produced. The notice under Section 148 was quashed, making all additions unsustainable.
ITAT upheld addition under Section 68 as the assessee failed to prove identity, creditworthiness, and genuineness of unsecured loans. It ruled that mere submissions without proper evidence do not discharge the initial onus, and addition was rightly sustained.
ITAT held that interest earned by a co-operative society from deposits with a co-operative bank qualifies for deduction under Section 80P(2)(d). It ruled that such income remains eligible despite Section 80P(4), and addition made by CPC was deleted.
