The Tribunal held that the assessee established a prima facie case regarding deduction eligibility for habitable-unit expenditure.
The Court reviewed bogus purchases of Rs. 4.65 crore, confirming the purchases as unverifiable but reduced the income estimation from 12.5% to 8%. The appeal was partly allowed, providing relief to the assessee.
ITAT Delhi upheld that failure to pass a speaking order on objections under GKN Driveshafts makes reassessment void, dismissing Revenue’s appeal for AY 2012-13
ITAT Delhi ruled that section 153C notices for AYs 2010-11 to 2013-14 were time-barred, exceeding the 10-year limit from receipt of seized material. The Tribunal emphasized that jurisdiction under 153C requires both timeliness and relevance of incriminating material. All assessments were quashed.
The ITAT Delhi quashed reassessment for AYs 2017-18 & 2018-19, ruling that approvals from a lower authority instead of the one specified under Section 151(ii) are void. Revenue’s appeals were dismissed, emphasizing strict statutory compliance.
Revenue’s claim of short-term gains was rejected; ITAT held that shares received as a gift inherit the donor’s acquisition date and holding period, validating LTCG and section 54F exemption.
ITAT Delhi held that reopening of assessment under section 147 of the Income Tax Act, solely on the basis of information received, without application of mind is bad-in-law and liable to be quashed. Accordingly, appeal of revenue dismissed.
Tribunal remanded the case to the AO to reassess ULIP maturity receipts treated as unexplained investment after the exemption claim was not evaluated earlier.
Tribunal held that AO did not establish any defect in identity, genuineness, or creditworthiness of share subscribers. Addition under Section 68 was deleted.
Tribunal emphasizes requirement of notice under section 153C for assessments in block period, quashing AY 2021-22 assessment framed without jurisdiction.