Tribunal ruled that an unsigned and uncorroborated loose sheet lacking essential transaction details could not form the sole basis for an addition. It held that documentary evidence and purchasers’ statements rebutted the presumption arising from the seized document.
The Tribunal held that an addition under Section 69 could not be sustained solely on the basis of a seized loose sheet without independent evidence proving payment of on-money. It upheld the deletion after finding that the Revenue failed to corroborate the alleged unexplained investment.
The ITAT held that limitation under Section 153B must be determined based on the assessee’s own last panchanama despite a joint search warrant. As the assessments were completed beyond the prescribed period, they were quashed.
The ITAT Hyderabad held that the assessment orders were time-barred under Section 153 despite the DRP process. Both assessments were quashed after applying the limitation prescribed under the Act.
The ITAT held that limitation under Section 153B had to be computed from the searched person’s last panchanama, making the assessments time-barred. The assessment orders were therefore quashed.
The ITAT Hyderabad upheld deletion of a ₹68.75 crore Section 68 addition after finding that the partner had established the source of capital contribution through sale proceeds of land. The Tribunal held that documentary evidence sufficiently explained the capital introduced into the firm.
The Hyderabad ITAT restored the issue to the Assessing Officer to verify whether project support and business development costs qualify as Head Office expenditure under Section 44C. It held that the classification requires factual verification before deciding the allowable deduction.
The ITAT held that Section 50C only substitutes the sale consideration for capital gains computation and does not prohibit deduction of the indexed cost of improvement. The matter was remanded only to verify the amount claimed.
A belated filing of Form 3CLA was a curable procedural defect and could not deprive an assessee of weighted deduction under section 35(2AB) where the substantive conditions for allowance of the deduction stand fulfilled.
The Hyderabad ITAT held that incomplete data retrieved from an inoperative computer could not prevail over audited books of account. It deleted the addition after finding no evidence of suppressed receipts or unexplained expenditure.
