Despite disputes over agricultural income additions, the Tribunal focused on the legality of the proceedings. It held that issuing a notice to a deceased taxpayer is a substantive illegality and cannot be treated as a curable procedural defect. The assessment was quashed.
The tribunal considered whether inconsistent explanations alone justify treating cash deposits as unexplained income. It held that suspicion cannot replace evidence and additions require proper investigation.
The tribunal examined whether the reasons given for late filing of the appeal were sufficient. It ruled that routine administrative workload and grievance handling cannot explain a substantial delay.
The tribunal considered whether CPC could rely solely on the original tax audit report to make an adjustment. It held that corrections through revised reports and financial records must be examined before sustaining an addition.
The case involved CPC adjustment denying deduction for employees’ PF contribution deposited after statutory due dates. The tribunal ruled that before the Supreme Court’s later decision, the issue was debatable and could not be adjusted under Section 143(1).
The Tribunal ruled that unverified KOT data and handwritten loose sheets are insufficient to establish unaccounted sales. Additions based on assumptions and unsupported survey statements were deleted.
The Tribunal held that immunity under Section 270AA cannot be denied due to technical issues in filing Form 68. The penalty under Section 270A was set aside and the matter was remanded for reconsideration.
The Tribunal ruled that collection of fees by an educational trust does not negate its charitable character. Where donations and fees are separately accounted, denial of 80G approval is unjustified.
The Tribunal ruled that denying the entire construction cost while computing capital gains is unjustified. The Assessing Officer must verify the valuation report and determine a reasonable cost of construction.
The Tribunal ruled that reassessment proceedings initiated against a dead person are void in law. A valid notice must be issued to the legal heirs under Section 159 before initiating reassessment.
