ITAT held that mandatory interest can still be examined for correct computation. CIT(A)’s ex parte dismissal without merit-based adjudication was set aside.
ITAT Delhi held that applying the gross profit rate of a different assessment year was excessive. It reduced the addition to 1% GP while holding that purchases still required proof of genuineness.
The Tribunal ruled that proceedings initiated under the old Section 153C framework after the Finance Act, 2021 amendments were legally unsustainable. It set aside all assessment orders for want of jurisdiction.
The ITAT Delhi held that the CIT(A) must pass a speaking order under Section 250(6) and cannot dismiss an appeal solely for non-compliance. It remanded the matter for fresh adjudication after granting proper opportunity to the assessee.
The ITAT Delhi held that the Assessing Officer could not make a disallowance under Section 14A when the case was selected only for limited scrutiny regarding deduction under Section 57. As no approval for complete scrutiny was obtained, the addition was deleted.
The ITAT held that a penalty under Section 271AAB cannot survive where the show cause notice fails to specify the exact statutory clause invoked. It ruled that such a vague notice violates the requirement of informing the assessee of the precise charge, leading to deletion of the penalty.
ITAT Delhi held that the CIT(A) validly remanded a best judgment reassessment after repeated non-compliance by the assessee. The Tribunal ruled that the proviso to Section 251(1)(a) empowered the appellate authority to order a fresh reassessment.
The ITAT Delhi deleted the addition under section 69A after finding that the assessee had substantiated the source of the jewellery through a Will, affidavit, purchase bills, bank statements, and other documentary evidence. It held that the jewellery stood satisfactorily explained.
The ITAT Delhi upheld the deletion of an ₹80 lakh addition after holding that the assessee had established the identity, creditworthiness and genuineness of the lender companies. The Tribunal ruled that additions cannot rest solely on suspicion of circular transactions without corroborative evidence.
The ITAT Delhi held that deduction of TDS by the payer does not by itself establish that income has accrued to the recipient. It ruled that income must be recognised based on the assessees accounting method and completion of services.
