ITAT ruled that a 76/23 split in chats reflected proposed refurbishment costs, not undisclosed cash consideration. In absence of corroborative material, addition under Sections 69 and 115BBE was held unsustainable.
Holding that the Assessing Officer recorded a mechanical satisfaction note without concrete incriminating evidence, the Tribunal dismissed the Revenues appeals and confirmed invalid jurisdiction under Section 153C.
The Tribunal held that non-filing of Form 10CCB along with return is a curable defect. A genuine start-up cannot be denied deduction under Section 80-IAC merely on procedural grounds.
ITAT held that a portion of cash paid could reasonably be sourced from accumulated withdrawals from joint bank accounts. The remaining unexplained amount was reduced on an estimated basis.
The Tribunal held that assumption of jurisdiction under Section 153C was invalid due to a defective and consolidated satisfaction note. As the mandatory requirement of year-wise satisfaction was not met, the entire assessment was quashed.
The Tribunal held that acceptance of returned income without examining material indicating possible unaccounted cash investment amounts to lack of inquiry. Section 263 revision was therefore lawfully sustained.
ITAT ruled that once cash sales are recorded in audited books and accepted by the AO, taxing the same deposits again would result in double addition. The deletion of ₹1.54 crore was upheld.
The Tribunal held that reassessment beyond four years is invalid where the assessee had fully disclosed material facts during original scrutiny. In absence of failure to disclose, reopening under Section 147 was quashed.
The ITAT held that approval under Section 151 was invalid as the PCIT merely noted As per Annexure without independent satisfaction. The reassessment under Section 147 was declared void ab initio.
The Tribunal noted that the subject line of the approval letter excluded the concerned assessment year, evidencing lack of scrutiny. It held that such defective approval invalidates the assessment.
