Bangalore ITAT held that cash redeposited during demonetisation could not be treated as unexplained under Section 69A when the assessee established that it originated from earlier bank withdrawals.
Bangalore ITAT held that customer deposits representing sale proceeds could not be taxed in full as unexplained money under Section 69A. The Tribunal directed the Assessing Officer to estimate business income at 8% of the receipts, holding that only the profit element was taxable.
Bangalore ITAT deleted the addition under Section 69A after holding that the assessee had satisfactorily explained the source of cash deposits with supporting documents and the Assessing Officer failed to disprove the explanation.
The ITAT Bangalore held that cash deposits could not be treated as unexplained where they were sourced from earlier withdrawals from the same bank account. It ruled that, in the absence of evidence showing the withdrawn cash was used elsewhere, the addition under Section 69A was unsustainable.
The ITAT ruled that failure to produce confirmations from debtors did not justify additions where sales, ledger accounts, and sample invoices were already on record. It directed deletion of the additions after finding no contrary evidence from the Revenue.
The ITAT ruled that bonus payments recorded in a separate bonus ledger, audit report, and profit and loss account could not be disallowed merely because they were absent from the salary ledger.
The ITAT Bangalore held that cash deposits recorded in audited books of account could not be treated as unexplained merely because they included specified bank notes. Since the Revenue found no defects in the books or evidence of bogus receipts, the addition under Section 69A was deleted.
The Tribunal held that the ex gratia received under the BSNL Voluntary Retirement Scheme, 2019 qualified for exemption under Section 10(10B) and not Section 10(10C), following earlier Coordinate Bench decisions. It directed the Assessing Officer to allow the exemption after verification of the revised computation.
The case examined whether compulsorily convertible debentures should be treated as debt or equity for allowing interest deductions. The Tribunal identified this as the primary issue before determining the arm’s length price of interest.
The ITAT Bangalore held that, from AY 2018-19 onwards, Section 80AC makes timely filing of the return under Section 139(1) a mandatory condition for claiming deductions under Chapter VI-A. A return filed later in response to a Section 148 notice could not revive the claim for deduction under Section 80P.