Tribunal held that non-filing of submissions or non-appearance cannot override substantive justice. CIT(A)’s order confirming additions was set aside, and matter remitted for fresh hearing.
The ITAT Delhi invalidated assessments where the AO failed to record year-wise satisfaction linking seized material to the assessee. Proper satisfaction is essential for initiating Section 153C proceedings.
The ITAT held that unsecured loans totaling ₹1.05 crore could not be added under Section 68 where the AO failed to make any inquiry or issue summons, emphasizing that suspicion alone cannot justify additions.
PCIT invoked section 263 against an assessment under section 153C. ITAT held that without challenging statutory 153D approval, revision is unsustainable, emphasizing that 153D is a statutory safeguard.
PCIT challenged a 153C assessment under section 263. ITAT held that without annulling statutory 153D approval, revision is unsustainable, confirming 153D as a statutory safeguard.
ITAT Delhi held that reassessment under Section 147 is invalid if notice under Section 143(2) is not issued after filing of return. Entire proceedings quashed for procedural lapse.
ITAT Delhi held that Section 115BBDA applies only to Individuals, HUFs, and Firms. Dividend income of a registered trust remains fully exempt under Section 10(34), with the addition deleted.
ITAT ruled that CIT(A) must examine admitted additional evidences before sustaining AO’s net profit estimation. Matter restored to AO for fresh determination.
ITAT Delhi held that a loan used to repay a bank cannot be treated as a trading liability under section 41(1). Since no deduction was claimed earlier and no write-back occurred, the addition of ₹8.22 crore was rightly deleted.
ITAT Delhi held that Section 69C cannot be invoked when purchases are recorded in books, paid through banking channels, and sources are explained. Estimated profit addition of 12.5% was deleted.
