The Tribunal noted that share application money in the first year requires proper enquiry before invoking Section 68. Additions were deleted as statutory conditions were satisfied.
The Tribunal ruled that VAT collected but not credited to the profit and loss account cannot be treated as taxable income. Once substantially paid to the government, such liability cannot be added again as trading receipts.
The issue was whether a seized loose paper alone can justify an on-money addition under section 69. ITAT held that without independent corroboration, such addition cannot be sustained.
The Tribunal examined whether a single, consolidated satisfaction note for multiple assessment years meets the requirement of Section 153C. It held that such consolidated recording vitiates jurisdiction, rendering the search assessments void.
The case addressed the legality of assessments framed pursuant to a search when the satisfaction note lacked statutory particulars. The Tribunal quashed all assessments, holding them non-est in law due to invalid satisfaction.
Interest was disallowed treating the loan as bogus. Once the loan itself was held genuine, the Tribunal allowed the interest deduction. The ruling confirms that business interest cannot be denied without proof of sham transactions.
Authorities added ₹8 crore as unexplained investment in the wrong year. The Tribunal confirmed that the cash component belonged to a prior year. The ruling stresses year-specific taxation of undisclosed transactions.
The Tribunal examined whether a single approval could cover multiple assessment years in search cases. It held that separate approvals are mandatory for each year. The ruling underscores strict procedural compliance under section 153D.
While an error in computation was acknowledged, prejudice to Revenue was not established. The Tribunal quashed the revision for lack of both ingredients. The ruling clarifies strict thresholds for invoking section 263.
The case examined whether entire purchases could be treated as bogus when sales were undisputed. The Tribunal restricted the addition to 6%, holding that only a reasonable estimation was warranted.
