The issue was whether reassessment could be initiated for an amount implicitly accepted in original assessment. The Tribunal ruled that reopening amounted to change of opinion and was legally unsustainable.
ITAT Delhi held that cash deposits during demonetisation were fully explained by cash sales recorded in regular books. When books are not rejected and sales are accepted, separate addition is unsustainable.
The Tribunal ruled that section 234E fee cannot be imposed for periods before 01.06.2015. In absence of jurisdictional High Court ruling, the interpretation favourable to the assessee was adopted.
The dispute included disallowance under section 14A exceeding exempt income. The Tribunal upheld restriction of disallowance to the amount of exempt income and rejected a higher computation. The decision reinforces judicial limits on Rule 8D application.
The ruling clarifies that the benefit of extended timelines under TOLA was unavailable for A.Y. 2015–16. As a result, reassessment initiated after the cut-off date was held unsustainable.
ITAT held that employee stock option expenses are deductible as business expenditure. ESOP costs linked to employee compensation and revenue generation cannot be disallowed.
ITAT held that Section 153C proceedings were invalid as the relevant years fell beyond the six-year window. Time limitation goes to jurisdiction and cannot be cured later.
The Tribunal upheld deletion of additions where cash sales during demonetisation were backed by invoices, VAT payments, and statutory records. Statistical suspicion alone cannot override credible primary evidence.
The Tribunal held that a penalty notice which does not specify the exact charge is invalid. Failure to strike off the irrelevant limb shows non-application of mind and vitiates penalty proceedings.
The Tribunal held that assessments beyond the permissible six-year block under section 153C are invalid. Proceedings were quashed as the relevant years fell outside the statutory limitation.
