ITAT held that the Assessing Officer made a ₹50 lakh addition solely on estimation without any supporting material, and deleted the addition as no evidence linked the assessee to alleged bogus share transactions.
ITAT Delhi held that reassessment for AY 2010-11 was invalid since it exceeded the ten-year limitation from the search year. The notice was declared time-barred and issued without jurisdiction.
TAT Delhi held that a 153C assessment for AY 2012–13 was invalid, as the six-year block must be counted from date of satisfaction recorded by AO of non-searched person.
ITAT Delhi held that ten-year block under Section 153C must be computed from date AO of non-searched person receives seized material, not search date.
ITAT held that no addition under Section 69A was justified when the jewellery found during search was less than the amount already declared in wealth tax returns. Revenue’s appeal was dismissed.
ITAT held that once income is accounted in the Profit & Loss statement, further addition by the tax authority is unlawful. The order restores the correct claim of losses and eliminates double addition.
ITAT Delhi upheld deletion of additions under Section 68 after the assessee proved identity, creditworthiness, and genuineness of lenders. Interest disallowance was also deleted as loans were repaid and taxed transactions verified.
ITAT Delhi held that assessments for A.Ys 2011–12 and 2012–13 were invalid since they fell outside the ten-year block reckoned from the date of receipt of seized material. The Tribunal followed CIT v. Jasjit Singh (SC) and Ojjus Medicare (Del HC) rulings.
ITAT Delhi held that comparable controlled transaction cannot be taken as comparable to benchmark the international transaction. Accordingly, transfer pricing adjustment in respect of international transaction towards payment of royalty deleted.
ITAT Delhi held that a seized document mentioning ₹18 lakh could not, without corroboration, be treated as undisclosed income of Krishna Gopal Saraf, deleting the addition.
